ML24340A261
| ML24340A261 | |
| Person / Time | |
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| Issue date: | 11/21/2024 |
| From: | Office of Nuclear Material Safety and Safeguards |
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| Download: ML24340A261 (1) | |
Text
1 1
U.S Nuclear Regulatory Commission 2
3 TRANSCRIPT OF VIRTUAL PUBLIC MEETING 4
ADVANCE Act Section 206 - NRC Licensing at Brownfield Sites 5
https://www.nrc.gov/pmns/mtg?do=details&Code=20241407 6
November 21, 2024 7
1:00 p.m. - 5:00 p.m. ET 8
- ADVANCENRC 9
10 (Note - This transcript was automatically generated by Microsoft Teams. It is not an 11 exact transcription and may contain transcription errors. Minor edits have also been 12 made for clarity and to correct factual errors.)
13 14 Sarah Lopas: Good afternoon and welcome to the US Nuclear Regulatory 15 Commission's public meeting on Section 206 of the ADVANCE Act, which is 16 regulatory issues for nuclear facilities at brownfield sites.
17 My name is Sarah Lopas. I am a senior environmental project manager in the NRCs 18 Office of Nuclear Material Safety and Safeguards. I'm one of the project managers for 19 the brownfields effort. And Allen Fetter over here is my colleague in the Office of 20 Nuclear Reactor Regulation, and he's the other senior project manager for this effort.
21 I'm going to be facilitating today's meeting and trying to cobble along with the 22 technology, so please be patient with me as I move screens around and what not.
23 So I before I get off to the agenda and all that good stuff I do want to let Sam Lee 24 get us kicked off. He's our deputy director of the NR CS division of new and renewed 25 licenses and. That division is one of the sponsors of this ADVANCE Act, Section 206.
26 So, Sam. Thank you.
27 28 Sam Lee: So good afternoon, everyone, and thank you all for joining us today for 29 our public meeting on ADVANCE Act Section 2006 titled Regulatory Issues for 30 Nuclear Facilities at Brownfield sites. I would especially like to thank our panelists, 31 especially those who are here in person, and thank you and those who are joining us 32 virtually.
33 Make for making time to join us today to provide your views on this topic.
34 We're pleased to have representatives from government and industry, the Idaho 35
2 National Laboratories, Gateway for Accelerated Innovation and Nuclear the Electric 1
Power Research Institute, the Nuclear Energy Institute, Duke Energy, Energy, 2
Northwest, Oklo, and others. Thank you all for being here. While today's meeting is 3
focused on Section 206 and I'll touch just briefly on the ADVANCE Act. Generally, the 4
ADVANCE Act of 2024, which stands for Accelerating Deployment of Versatile 5
Advanced Nuclear for Clean Energy Act was signed into law in July 2024.
6 7
And it requires NRC to take a number of actions, particularly in the areas of licensing 8
of new reactors and fuels, while maintaining the NRCs core mission to protect the 9
public health and safety. These include implementing initiatives to achieve efficient, 10 timely and predictable license application reviews, establishing an expedited 11 procedure for reviewing qualifying new reactor license applications and others.
12 Including assessing the licensing review process for nuclear reactor facilities at 13 former fossil fuel plant sites, power plant sites and brownfield site, the focus of 14 today's meeting. The NRC endeavors to make the most of the opportunity provided 15 by ADVANCE Act to improve how we accomplish our mission. And we recognize the 16 importance of external stakeholder engagement and input into this opportunity, 17 which is why we are all here today. So, we are looking forward to our panelists 18 insights and a good discussion about how the NRC can facilitate licensing of nuclear 19 facilities at Brownfield and retired fossil fuel sites.
20 21 So, thank you again for your participation today. And with that, I'll turn the mic over 22 back to Sarah.
23 24 Sarah Lopas: All right, everybody, so quickly to the agenda or the flow for really how 25 today's going to work. We're going to start with four presentations.
26 Our presentation, Idaho National Lab Gateway for Accelerated Innovation in Nuclear 27 (GAIN), NEI and then EPRI. After those presentations, I'm going to facilitate a short 28 discussion panel discussion between our panelists and our NRC staff.
29 Any panelists, colleagues that are out there online as well.
30 We then are going to have a short break after that.
31 Then we'll come back with the with some of the industry presentations from Duke, 32 Energy Northwest, and Oklo, Christine King from GAIN is going to come back and do 33 a little preview of workforce considerations, community activities. We'll have another 34 panel discussion and then we're going to open it up for public comments and 35
3 questions. So, everybody that's an attendee right now, member of the public, et 1
cetera, you are all in Listen only mode. When we get to the public comment part, I 2
will be walking you through how to, you know, raise your hand and we'll unmute 3
you. And there will be public discussion at the end of this meeting.
4 All of these presentations - or I'm going to just double check with all our presenters 5
whether or not I can share their presentations publicly, put them in ADAMS, if I can, I 6
will be updating the public meeting notice with links to all the slides today. I am 7
recording today's meeting. There will be a transcript that I'll be making publicly 8
available at some point, and that's going to inform our meeting summary.
9 So there'll be a meeting summary. But I will not be making the actual video of this 10 meeting public, just to let everybody know. Just answer that question up front.
11 And I think with that, that might be all I have. So, at this point I'm going to turn the 12 meeting over to Shilp. Shilp Vasavada is one of our ADVANCE Act team members in 13 the office of the Executive Director for Operations, and he's here on behalf of OEDO 14 to kind of walk us through the next couple slides. Shilp.
15 16 Shilp Vasavada: Yeah. Thanks, Sarah. So as Sarah introduced me, I'm part of the core 17 team in the office of the EDO, overseeing the agency wide implementation of the 18 ADVANCE Act. First of all, again, as Sam said, wanted to thank everyone of you in 19 person virtual for being here and for your interest in this topic. As Sam said and I 20 wanted to reiterate, today's meeting is about a specific piece of the ADVANCE Act, 21 Section 206 related to regulatory issues.
22 Our nuclear facilities at brownfield sites and to facilitate a productive and focused 23 discussion. I would encourage everybody to keep their comments, feedback, 24 questions. Focused on this particular piece of the ADVANCE Act, as you, the public 25 meeting was noticed on November 7th [2024] with the hashtag advance NRC to 26 identify as a public meeting related to the ADVANCE Act.
27 Next slide please.
28 As everyone knows, there's a lot happening at the NRC with the ADVANCE Act, the 29 ADVANCE Act has a lot of actions and we have a dedicated public website that I 30 would encourage all of those who are interested to go to.
31 You can find it from NRCs public webpage nrc.gov on the spotlight section on your 32 left. It's the third from the top. ADVANCE Act. That'll take you to a public website.
33 Uh, the QR code over here on the slide will take you to an interactive public 34 dashboard. A picture of which is on the slide, which gives you information about 35
4 perspective of all the actions that we are taking. And then if you hover on any of the 1
tracking bars, you can see key milestones for each of these actions.
2 So you can be aware of what's happening on any and all of all of them.
3 On the public website, we have also started to put to put up important documents 4
coming out of each of these actions as they become available. So you have one stop 5
repository for all of those key documents.
6 Next slide.
7 Let me see. This particular slide in the QR code will take you to the portion of the 8
public web page which gives you information on both the past public meetings 9
related to the ADVANCE Act, as well as upcoming public meetings. So again, you 10 have one place to look at these whenever the public meetings are noticed. Project 11 teams use the hashtag #ADVANCENRC. And once they do that, all of the public 12 meetings are collected over here. So you can go over here and keep abreast of 13 what's happening in terms of the different actions and what the different project 14 teams are doing, including this one.
15 Next slide please.
16 And lastly on this slide and the QR code, it'll take you to the place to provide 17 feedback.
18 Any questions, any ideas or comments that you may have on everything related to 19 the ADVANCE Act that the NRC is doing, including section 206, but if you have any 20 thoughts or ideas for items beyond section 206, this is the place to do it and then we.
21 Feed that to the appropriate project teams for consideration as they continue with 22 their actions. So again, once again, thank you for your time and for being here.
23 We look forward to a productive discussion, and with that I'll turn back to Alan Fetter 24 to continue the meeting. Thank you.
25 26 Allen Fetter: Okay, thank you Shilp. Good afternoon, everyone and welcome.
27 I'm again. I'm Allen Fetter, senior project manager in the Office of Nuclear Reactor 28 Regulation. Sarah and I are co-leading this effort as she mentioned, to evaluate the 29 extent to which modification of regulations, guidance or policy are needed to enable 30 the efficient, timely and predictable licensing reviews and support the oversight of 31 production and utilization facilities at brownfield sites. So I'm helping lead the safety 32 aspects of this effort, and Sarah's focus on focusing on the environmental efforts, but 33 there is some crossover, so working as a team, obviously now the objective is of 34 streamlining licensing of NRC facilities at or near Brownfield or Retired fossil fuel 35
5 sites by leveraging the existing infrastructure, emergency planning and 1
organizational planning, as well as the availability of historical site specific 2
environmental data previously completed, environmental reviews and activities 3
associated with potential decommissioning facilities and remediation, and we're also 4
looking at community engagement and historical experience with energy production.
5 Next slide please.
6 The NRC's evaluation of 206 will focus on both brownfield sites as defined by the 7
CERCLA. You don't have to say the whole thing, and retired fossil fuel sites.
8 The scope of the staff's brownfields valuation will include safety, security, emergency 9
preparedness, financial, environmental, construction, oversight and community 10 engagement considerations. To determine the potential regulatory issues of citing an 11 operating production or utilization facilities at or near brownfield sites.
12 The staff will review currently available information and guidance, both internal and 13 external, and examine past licensing reviews. Oversight activities and lessons learned 14 from other applications and facilities at or near brownfield sites.
15 Next slide please.
16 So the NRC has already worked with the licensing of brownfield sites and will be able 17 to leverage these experiences for future applications. This slide shows some 18 examples. The Clinch River site had some prior development and some on site 19 contamination, some of which may have come from off site, was identified during the 20 ESP review and that site was licensed sites just North Anna 3 and Vogtle units three 21 and four are located on previously developed sites with industrial operations and 22 some contamination was identified during those reviews. The PSEG site near Salem 23 and Hope Creek is an area that prior industrial and ongoing activities. Industrial 24 activities on it and adjacent to it and specifically for the ESP site they were going to 25 use Artificial Island, which was a former Army Corps. of Engineers dredge spoils. Site 26 and it was covered with the, you know, PCBs and heavy metals from the Delaware 27 River. So, these sites can be reviewed again to identify lessons learned from these 28 previous licensing action and oversight to support the NRC assessment of any 29 changes. The regulation guidance, as well as aspects that will make more time and 30 provide efficiency gains.
31 Next slide 12.
32 So the staff will, as mentioned before, explore the potential reuse of existing site 33 infrastructure and how it could expedite safety licensing review reviews at brownfield 34 sites. Electrical, for example electrical switch components and transmission 35
6 infrastructure. Heat sync components and steam cycle components. One thing that's 1
important is consideration of different reactor sizes and types will be factors in this 2
evaluation. It's very important.
3 Next slide.
4 The reuse of electrical switch charge and transmission lines for nuclear plants can 5
result in expedited NRC reviews if the plant nuclear safety design is not dependent 6
on A/C electric power and satisfies FERC, which is the Federal Energy Regulatory 7
Commission, and NERC, the North American Electric Reliability Corporation standards 8
for grid interface. Of the nuclear generator based on the electrical power output, 9
reactive capability, and power ramping control capability.
10 As it also says on the slide, opportunities for additional time savings in our reviews, if 11 passive plant designs and systems do not rely on off-site A/C power plan to be used.
12 The next slide.
13 The reuse of water supply, heat sink and steam cycle components, these will also will 14 depend on the plant design and demands and the considerations is the water 15 quantity, water quality and temperature are certain constraints on water temperature.
16 There's also the Clean Water Act, which cover certain temperature constraints, and 17 that this is where we have crossover into the environmental.
18 There's also risk evaluation. Some of these sites, if we were looking at Brownfield site, 19 might not have had the same seismic evaluations and the flooding needs to be 20 looked at to meet NRC standards. And use of existing structure systems and 21 components will depend on the specifics of the chosen reactor design and or prior to 22 meeting applicable regulations.
23 All right. Next slide.
24 So, the staff will also evaluate how safety license reviews of brownfield sites could be 25 expedited by leveraging existing early site permits, the use of plant envelopes for 26 similar sites, standardized parameters on a portion of a larger site and standardized 27 applications for smaller sites.
28 Next slide.
29 Staff will also evaluate site specific characteristics for physical security already 30 encompassing our regulations and guidance and any implications for brownfield 31 sites and for emergency planning. Evaluate whether an applicant's hazard analysis 32 required for EP could be impacted by Brownfield sites.
33 The next slide.
34 And thank you and I'll turn it back over to Sarah.
35
7 1
Sarah Lopas: Yup, this is me. So obviously for energy producing brownfield sites, 2
reuse of existing infrastructure like roads, rail lines, T lines could simplify the 3
environmental review just by reducing the impacts to the local environment.
4 So for example, impacts to historic and cultural resources generally using previously 5
disturbed industrial sites for construction and reusing existing infrastructure could 6
minimize impacts to historic and cultural resources. So while that could simplify our 7
evaluation - however, we are still going to have to consult under section 106 of the 8
National Historic Preservation Act, you know, with the State Historic Preservation 9
Office, and effected tribes and Native Alaskans on that undertaking.
10 But I'll note that for all of our environmental reviews, the NRC is working really hard 11 at making those consultations more effective and efficient. And a lot of that has to 12 do with early engagement with some of those affected parties.
13 So we're working on that for sure.
14 And like with Greenfield sites, to expedite the environmental reviews at brownfield 15 sites and to streamline the NEPA document, we're going to rely on previous studies 16 of the site. So that would include any existing NEPA and permitting agency 17 documents and, for example, existing biological sampling data and surveys that may 18 exist could help streamline Section 7 consultation under the Endangered Species Act.
19 So the NRC would of course also leverage pre application engagement, which we 20 expect there would be a lot maybe with the Brownfield site.
21 And, of course, we're going to use all the available environmental review efficiencies 22 that are currently being implemented as part of the required recent changes to 23 NEPA, right? So clearly all the same efficiencies that were that were working on 24 applying now would apply to these the brownfield. But for section 206, we are going 25 to be taking a hard look at whether there are any additional regulatory or guidance 26 or process changes that will be needed. To really kind of expedite licensing of 27 brownfield. So, we would love to hear more suggestions from everybody out there 28 on that.
29 The next slide here is decommissioning.
30 So decommissioning considerations differ depending on whether we're talking about 31 licensing a new nuclear facility on a site previously used by a non-nuclear facility like 32 the coal plant in this photo or a site that already had nuclear on it or has nuclear on 33 it. So first I'll talk about licensing a nuclear facility on the non-nuclear site for non-34 nuclear sites. The US Environmental Protection Agency EPA and/or the applicable 35
8 state agency would have primary responsibility for decommissioning.
1 We expect the decommissioning considerations for licensing in a new facility will vary 2
depending on the type of Brownfield site being considered for reuse. We've started 3
interactions with the EPA to understand the remediation requirements and processes 4
to make future engagements on specific sites more efficient and effective, for 5
example.
6 Understanding EPA or state processes for releasing sites or parts of sites could allow 7
us to license construction activities for new nuclear facilities in non-impacted areas.
8 Build site earlier in the decommissioning process. There's also the possibility that for 9
some site sites, the measurements that EPA or the state requires to demonstrate that 10 a Brownfield site can be released from their oversight could contribute to the site 11 characterization data that the NRC requires for nuclear facility licensing.
12 So this next slide is going to cover for sites with an existing nuclear facility.
13 There are potential efficiencies for both decommissioning of the older facility and the 14 licensing of the new nuclear facility. So, for example, information that the NRC 15 requires decommissioning nuclear facilities to assemble about the previous uses of 16 the site, which we call historical site assessment information, could support the 17 release of portions of the site before complete site decommissioning, which would 18 allow an early start to construction for a new nuclear facility. Similarly, NRC 19 requirements for operating nuclear facilities, which are in 10 CFR 50.75 support good 20 documentation of past performance like you know, documenting leaks or spills so 21 that future decommissioning work for the new nuclear facility would be properly 22 scoped and addressed for effective cleanup in addition, costly and time-consuming 23 disposal of equipment and dismantling of buildings used by the decommissioning 24 nuclear facility could be streamlined. If the new facility could use that equipment or 25 buildings and accept them in a license transfer instead of the decommissioning 26 facility needing to terminate their licenses, which typically requires more technical 27 effort, our Technical Support, the transfer could result in cost savings for both the 28 decommissioning and nuclear and new nuclear facilities for the decommissioning 29 nuclear site, knowing that the land will be used by another nuclear facility could 30 simplify the analysis. The NRC requires the decommissioning nuclear facility to do.
31 To show that future use of the site is safe, which we call a dose analysis, that analysis 32 could be simplified because the NRC usually considers all reasonably foreseeable 33 uses of a site. So, for example, like someone putting a farm on the on the site in the 34 future, if the facility is in a rural setting, if the decommissioning nuclear facility 35
9 licensing knows the site's going to be used for new nuclear facility, then they might 1
not need to considered. The more complex exposure path pathways, like someone 2
growing crops or raising animals on the site. So, there are financial considerations 3
too. There were that we're going to look at. So current financial qualifications, 4
decommissioning, funding and insurance and indemnity regulations and guidance 5
address the requirements regardless of citing. So, staff will evaluate potential 6
challenges to these financial equities and address them as necessary and 7
appropriate, whether that's through guidance or rulemaking such as the residuals of 8
Radioactive contamination from prior site activities, for example coal combustion, 9
residual storage in landfills or ponds to ensure the accuracy of cost estimates for 10 every phase of the reactor. So, construction operation, decommissioning the 11 applicant or licensee will be the thorough understanding of potential radioactive 12 waste and residual radioactive material located at the site. The applicant would need 13 to provide a discussion in the application of what the potential liabilities are, what 14 each party is responsible for and or arrangements for addressing such liabilities, for 15 example, radioactive material not affiliated with the reactor operation.
16 And last but definitely not least is community engagement.
17 So subsection 206(C)(2)(F) requires consideration of community engagement and 18 historical experience with energy production. So, with regard to community 19 engagement, the NRC's NEPA reviews already necessarily include community 20 engagement, public comment periods, outreach to tribal governments to state and 21 local governments. You know all the formal consultation we must do, so the staff will 22 assess whether current community engagement, best practices, best practices.
23 Need to be modified at all, considering community experience with that brownfield.
24 The community's historical experience with energy production will factor into the 25 NRC socio economic evaluation in May. Also factor into the environmental justice 26 impacts. Every site will obviously be different, but you know there's likely to be 27 economic benefits related to re-energizing the shuttered site. Right? Related.
28 To this workforce impacts on the community if there are environmental justice 29 populations located around the site and for example, we're looking at maybe nuclear 30 replacing of retiring coal facility, that could be a consideration that factors into the 31 environmental justice analysis.
32 All right. And this is our last slide here, finishing up on time, Allen.
33 Good for us, a little bit early.
34 These are our big milestones. So, we have a report to Congress due in September 35
10 2025. We have a little bit of an interim report due to our Commission ahead of this, 1
so that's why we're really working hard right now to get that report together for our 2
Commission. We then have to develop some strategies, implement those changes or 3
initiate rule making by July 2026. So, these dates are coming right out of the 4
ADVANCE Act. So, they are set for us and then we have another report due to 5
Congress in July 2027 that's going to document what we did. So that is those are the 6
big picture milestones there and I just wanted to add that the feedback that we get 7
from you during this meeting and also subsequent comments from you in the public 8
will help inform the report that we develop. Yeah, I really appreciate this opportunity.
9 All right. So, if you just give me a moment here, Next up, we are going to have so 10 Idaho National Laboratory Gateway for Accelerated Innovation in Nuclear (GAIN).
11 We're going to have Christine King, who's the director of GAIN, and Doug 12 Hardtmeyer, who is a senior nuclear engineer at MPR Associates working with GAIN 13 present to you. So, Christine and Doug, if you just give me a moment. I just have to 14 kind of scamper through the presentation here.
15 16 Christine King: Well, Sarah, while you're scampering.
17 I will start with an introduction before Doug gets into the nuts and bolts.
18 So first of all, thank you to you and Allen for the opportunity to share the work that 19 we have been doing along with our colleagues in industry. Several years ago, there 20 was a top-level document written with what I would say the idea of coal to nuclear.
21 And we again decided that there were a lot of good reasons.
22 Or looking into this, the Department of Energy did a report in 2022 that underpinned 23 and helped us with where we started. We're going to show a little bit of that work.
24 That work has gotten a lot of press associated with it, but that report looked at 25 operating and recently retired coal stations and did an initial siting evaluation.
26 It's not a full siting. It was a screening. To see how many coal sites might be viable for 27 either an advanced reactor or a large light water reactor, and what we found is that 28 there's actually hundreds. It is only an initial screening. And so, what we wanted to 29 do in the work at GAIN was really look at what you were talking about earlier that 30 that non-nuclear to nuclear transition. From the point of view that it may be a higher 31 hurdle for a utility that does not have nuclear in their portfolio. And so we're going to 32 talk today about not only some of the work that we've done, but along the way, 33 some of the work that we've become aware of and how we've knit that together.
34 And tried to crosswalk what we've learned over the past few years to the questions 35
11 that were posed to you for the ADVANCE Act so.
1 We hope that this information and the work that we've done is helpful into the to the 2
work that you need to do.
3 And I'm happy that NEI and EPRI will follow with the detailed work that we have 4
done.
5 I'm proud to say over the past few years we have all worked to make sure that we 6
were not duplicating work in this space.
7 We were really trying to build a broad knowledge base.
8 So over the next few presentation sets, which you'll see NPR Associates has been our.
9 Our engineering research team.
10 On the backside of the gain work on our pilot studies, they've been very good 11 partners to us and they're partnering with us also in some Community efforts that I'll 12 talk about at the end of at the end of the day today.
13 With that, I'm going to turn the presentation over to Doug.
14 I'm here. Doug, if you need me. But you probably don't. So, take it from here.
15 16 Doug Hardtmeyer: Well, don't. Don't get too far away there and you know, so good 17 afternoon, everyone. My name is Doug Hardtmeyer as mentioned. I work for MPR 18 Associates were based out of Alexandria, VA, and for the last three or so years, really, 19 we've been working very closely with gain and sort of the larger research teams at 20 EPRI and NEI on what does it look like for retiring coal station owners to repower 21 with nuclear.
22 And so if we go to the next slide, what we're really hoping to do today is go over 23 some of the just key takeaways that we got and what our overall approach was for 24 looking at a handful of different stations across the country with very different you 25 know site locations, backgrounds. You know, different interests driving the decision 26 to consider nuclear. And really get into some of the tangible pieces you know that 27 we saw from an engineering perspective when it comes to using site guidance and 28 different industry guides and some more of the intangible aspects too, especially as 29 it ties into Community support. And so hopefully with that we'll get a clearer picture 30 in the room and with everyone online. Just what things we saw at high level that 31 could be potential areas for Brownfield redevelopment opportunities here and then I 32 know Daniel and Kati will both go into a little bit more of the specifics and where 33 we're seeing those opportunities.
34 If we go to the next slide.
35
12 So if we take a look at the different sites where GAIN had evaluated, we looked at a 1
station in Arizona, particularly the eastern half of Arizona called Coronado, which is 2
owned and operated by the Salt River Project and a few other owners too, in 3
Kentucky, the Ghent Generating Station, which is just to the southwest of Cincinnati 4
on the Ohio River and sort of the northern tip of the state there. And then the 5
Colstrip Power Plant up in Colstrip, Montana. So the eastern part of the state and 6
each one of those sites and locations had a bit of a different background and story 7
going for them.
8 For Coronado specifically, they are directly next to Navajo Nation and the town of St.
9 John's itself, the vast majority of the people there work at this cool station.
10 And have a vested interest in seeing what will replace that station when it retires and 11 so there's there. They had a lot of nearby industrial customers such as Nucor Steel, 12 Dow Chemical, you know, being right on the Ohio River valley there in Appalachia, 13 there were a lot of opportunities there for potential beyond electricity approaches.
14 And then lastly for Colstrip, this is an interesting one because the water that's used to 15 cool the plant currently is also the main water source for the town and the town itself 16 has only about 3000 people as well. But different sort of motivating factors all in 17 common, I'd say is that the need for family sustaining jobs and just seeing what 18 would happen with these sites in the future and for each one of these, we took a look 19 at from, you know, a siting perspective, what might need to be in place for nuclear 20 deployment.
21 What types of technologies are suitable for me, not only the community's needs but 22 the utilitys needs? And then also, what types of economic impacts could happen?
23 Should a station like Ghent Station shut down or be replaced with various scales of 24 nuclear capacity? Go to the next slide.
25 Taking a look at a lot of the different references that we folded into these 26 evaluations. There's a number of different guides out there.
27 Currently we try to cast a wide net, not only from our friends at NEI and EPRI, but 28 also taking into account some of the newer guidance and some tried and true 29 guidance from the NRC when it comes to citing in particular. So, we definitely heavily 30 leveraged Reg Guide 4.7 and then also the new draft of the new nuclear reactor, 31 generic environmental impact statement NUREG-2249 especially for the Colstrip 32 study. You know, taking a look at how that could factor into different environmental 33 reports and if that could be used for these stations in particular.
34 But again, a lot of this stuff, well, this was excellent for providing the sort of tangible 35
13 engineering related aspects there.
1 There's a multitude of different softer type of issues to consider here as well, and 2
making sure that the social effects with balance with you know, the engineering 3
practicalities of nuclear as well.
4 Go to the next slide.
5 Certainly the biggest area of opportunity where we saw potential for increased 6
collaboration or guidance from the NRC helping these non-nuclear owners was from 7
a siting perspective and just the different moving pieces that go into clearing a site 8
for nuclear usage. And so, what we looked at in particular, was screening all of these 9
sites for any factors that would outright preclude nuclear construction? Anything that 10 is a non-starter type issue and then some of the other grayer topics - I'll put it that 11 way. You know, while there are a number of different guides talking about things like 12 site seismicity and things like that, you know the question there really is how much 13 would an owner want to invest in developing that site from a safety or environmental 14 perspective before choosing an alternative site, which may be a better site.
15 So if we look at the two studies which we've completed, so with Coronado and 16 Ghent, we've, we've wrapped those up and a lot of those reports are publicly 17 available. The Colstrip site is still in in under evaluation there, but many similar 18 insights that we're seeing from these first two.
19 So for Coronado specifically, they had a very large site. They were diligent in terms of 20 capping their CCRs and moving that to dry ash storage and you know, really didn't 21 have a lot of concerns from that perspective. A lot of for them what they would need 22 to consider going forward, no surprise. Being in Arizona is a water acquisition 23 strategy and what that might look like going forward, especially with water scarcity 24 and conservation efforts underway.
25 The other thing there be an Arizona home to over 74 different endangered or 26 threatened species. Taking a look at what those impacts could be from an 27 operational construction standpoint as well, but one thing that we'll get to is talking 28 a little bit about the programs that they already have in place for that. And so that 29 was Coronado in a nutshell. And then for Ghent, little bit of a different story there.
30 While the site itself was again feasible from our perspective and the criteria that we 31 looked at, their considerations were a little bit different in that they had a smaller site 32 being located in Appalachia. Slope was definitely a concern, and so the cost to grade 33 land and from that perspective may become challenging. And then given the 34 changes in ownership of the site and the way that the CCRs were stored on site, 35
14 some of that would need to be remediated for potential nuclear deployment down 1
the road. So they were a little bit land limited from that perspective.
2 Go ahead to the next slide.
3 So I kind of teased on it already here, but when we think about what we took away 4
from this and what may be applicable in particular to this, this question of what can 5
we do with brownfields, a lot of this has a common theme of equivalency of 6
information. Of workforce and just what from that current station can I pull forward?
7 So there's the infrastructure piece which I know Daniel will talk a little bit about.
8 In terms of what people are thinking about reusing from a physical asset standpoint, 9
but also a lot of these coal stations too have very similar programs, not to quite the 10 NQA level, but you know similar programs such as environmental monitoring, 11 meteorological monitoring, groundwater monitoring, all sorts of things.
12 That way and leads these sites being extremely well characterized, especially because 13 it currently has to support.
14 A generating station itself.
15 One of the common things that we saw there was why can't we leverage some of this 16 information for potential licensing basis going forward, right? If we are able to prove 17 that there is an equivalency there or that the results can be supplemented with you 18 know some other types.
19 Of studies during citing what might that look like and how could that potentially 20 streamline the process?
21 In addition to that, you know, besides just the programs in place that you know a 22 met tower or things like that, a lot of the softer programs like environmental 23 monitoring and compliance with different state and federal regulators for 24 endangered species protection and EHS programs there seem to.
25 Be a lot of similarities there from what we've seen, just with our familiarity with how 26 nuclear plants operate currently. And then lastly the workforce piece of this too, was 27 another opportunity there.
28 So I mentioned that for a lot of these towns, being that this coal station was the 29 economic driver for a lot of these facilities, the question first and foremost, both of 30 the communities and the utilities was how can we make sure that these workers 31 aren't left behind? During an energy transition and so looking across some of the 32 skill sets and talents that they already brought to bear.
33 There is, and there's an economic report that that looked at this about a 74%
34 overlap. When you take a look at the trades that are involved at a current coal station 35
15 and could potentially be you or you leveraged again at a nuclear station. Right. And 1
so understanding what sorts of training and qualitative transition.
2 Go ahead to the next slide.
3 So taking another step back and thinking about what sorts of benefits that these 4
brownfield sites have to offer, we can think about the data that currently exists with 5
these sites and how this is a well characterized site already supporting power 6
operation and how that might be able to be carried forward for future licensing 7
efforts, operational efforts, etcetera.
8 And then lastly, sorry, not lastly - next thinking about the reduction in emissions and 9
how? Using a well characterized site already zoned for electricity production can 10 potentially help preserve future Greenfield sites or just, you know, leave other sites 11 untouched. From that perspective and thinking of what that means from an 12 environmental and energy justice perspective. And so, if you think about specifically 13 what the NRC may wish to consider, and I know Daniel and Kati will talk in a little 14 more detail about these sorts of things is just talk about, well, how site monitoring 15 programs could potentially be pulled forward. Be it the groundwater, meteorological 16 or anything else that's used in the day-to-day operation of these facilities, and then 17 also how the current compliance with state and federal regulators, entities, 18 stakeholders could potentially be solicited for feedback and information, potentially 19 leading to expeditious and efficient reviews of those sites. So, you know, just to note 20 too, before we go to the next slide, just these are all things from GAINs perspective 21 and what we saw working with these coal stations.
22 I will say you know another key piece too. If we go to the next slide.
23 It was nice for me to get out of the ivory tower of engineering, so to speak, and you 24 know, I just mostly live in PowerPoint space these days. But getting to travel to these 25 communities talk with the different community members there and understanding 26 just the level of support that was there for a future project like this. And so speaking 27 just from, you know, my independent perspective on this, you know, when a utility 28 will announce that a coal station will potentially close and they may or may not be 29 considering you know, putting a new asset there, a lot of the feedback that we had 30 seen from these public settings was a general excitement towards nuclear and the 31 prospects of that simply because of the potential to keep jobs, the economic drivers, 32 the tax benefits from all of.
33 This was definitely leading to a groundswell of community support, and the utilities 34 definitely took notice of that you know, they, they saw this as an opportunity to 35
16 sustain. Various regions that they've been a part of for the last 40, 50, 60 years.
1 And saw this as a great way to maintain that relationship.
2 The other piece of this too, that that helped from a technology assessment piece was 3
taking a look at you know the engagements that different reactor technology 4
vendors had had with the NRC and going through some of the White Papers and 5
licensing topical reports to try and understand from a maturity perspective.
6 How these facilities may be able to sit in with a town or coal station?
7 So, you know, taking all of this in aggregate, there's certainly.
8 And I'd say a lot of different environmental justice, technical socioeconomic type of 9
considerations there that make this worth investigating and appreciate the 10 opportunity to get to talk with everyone here today about those, those pieces that 11 we saw during our investigations.
12 I believe this is the last slide.
13 Lastly, you know speaking on the just ground swell and incitement around the 14 excitement around the topic there in addition to some of the Colstrip work that we 15 have going on gain and others across the Department of Energy are involved with 16 the communities leading energy action program which is focused on making sure 17 that folks aren't left behind in the energy transition.
18 Process that we're seeing fold out across the country and so there are multiple 19 projects all in the spirit of that are currently ongoing, all in the spirit of how can we 20 potentially leverage nuclear to ensure that we're not left behind, right. And so 21 replacing coal assets or things of that nature has definitely been a common theme 22 with a lot of these different areas, and just to give you a flavor for these regions in 23 particular, they have a very high share of the coal generation currently and are 24 looking at ways to get involved with this piece so all of this work too, and to some 25 degrees too we'll be able to publish it. We're scheduled to complete all these 26 projects by the end of the calendar year 2025 and always happy to talk more about 27 what we're seeing if there's any additional perspectives.
28 I think this is the last one.
29 30 Christine Palmer King Yeah. And in terms of our ongoing in terms of our ongoing 31 work and the stuff that Doug presented, it is important to note that in several cases, 32 our work emerged from contacts that initiated with the Community and not from the 33 utility itself, and the utilities have been great partners along with the communities in 34 the pursuit of this work. A lot of our work in these early projects is really thinking 35
17 about how these communities can move independently of the utility, or at least 1
parallel to the utility, while the utility is considering what they might do with that site.
2 So, the work that you're doing around the ADVANCE Act will give them a little bit 3
more autonomy and so I you know, as we go forward, I do think there is a 4
community voice. I think Doug said it while we spent a lot of time in these 5
communities and we're pleasantly surprised at the amount of interaction that we had 6
with, with the work that we were doing. We'd be happy to share as much as we can.
7 I also just want to flag some of our reports from the pilot studies do have business 8
sensitive information in it from the utilities, so if you request that information, we 9
might have to figure out a pathway by which to share that that that information 10 remains protected. And with that, we'll turn it back over to you, Sarah. Thank you so 11 much.
12 13 Sarah Lopas: Next up, so we're going to hear from the Nuclear Energy Institute. Kati 14 Austgen, who is a senior project manager for new nuclear at NEI. So, Kati, I'm going 15 to just pull up your presentation here. Give me a moment.
16 17 Kati Austgen: Yes, thank you for anyone on the line who maybe doesn't know NEI is 18 an industry Trade Organization. We represent our over 340 members in advocating 19 for the beneficial uses of nuclear science and technology, we do that on the hill in 20 front of the NRC. We interact with the Department of Energy. And so I specifically 21 work with our new nuclear group. And so that's all of our members who are 22 interested in playing a part in the future nuclear deployments.
23 24 Well, thank you so much for the opportunity to share some perspectives here.
25 We can go ahead to the next slide.
26 27 So, part of the way NEI works because we are a membership-based organization is 28 that we invite all of those Members to participate in various committees and inform 29 our positions and inform the work. What is important about what NEI should be 30 doing so we recognize that siting - both the environmental and the safety aspects -
31 are a huge piece of looking at this widespread deployment of new nuclear 32 technologies. So, since 2021, we have been looking at coal to nuclear, but not just 33 coal to nuclear, really. Any aspects of siting and how can we be more efficient, more 34 streamlined. As I mentioned, we have the breadth of the nuclear industry as our 35
18 membership and so many of our Member utilities, new reactor designers, 1
engineering, procurement, construction and other professional service firms have all 2
participated in this task force. So, we have, we think, very good representation of the 3
different views of everyone who has some role in figuring out where nuclear sites 4
might be providing those applications to the NRC that then successfully make it 5
through the licensing process. As I stated, the goals of our task force are really to be 6
more efficient, so reducing the cost of the application preparation and the NRC 7
review, improving the approval, timeliness, all of that through preparing high quality 8
applications that provide exactly the information that's needed but not going over.
9 Or, you know, digging too far into something that wasn't important to the 10 environmental review or the safety review. Of course, we want to enhance the 11 flexibility of the regulatory process because if we see lots and lots of new 12 applications coming in, we're going to be able to shift and meet that moment. And 13 then of course, there may be common policy issues that come up and so a desire to 14 address those as well. Next slide.
15 So as I mentioned, we've been working for over three years now.
16 So what have we been working on? Some things have been just for our Members 17 and those are really informing their business planning. Things like looking at the 18 different States and what sort of state permits are required for a coal facility.
19 What's required for nuclear facility? What might be transferable?
20 What you know maybe needs a little bit of extra information. Where does the 21 process already exist to do that? Where is it unclear, but perhaps there is a process.
22 Of course, these are different for all the different states. We only looked at 5 different 23 states, but it gave us kind of a good sampling and so we're glad to hear that NRC is 24 working with other federal agencies and state agencies to think about how you can 25 interact earlier and leverage some of that information we would encourage you to 26 continue doing that and if there are any particular states or Members who are 27 working in different states that we could help suggest things that need to be looked 28 at. We would be happy to be happy to do so. We also looked at a federal level, 29 things like federal interconnection. So, there is a queue to put your power on the 30 grid.
31 And so how might those be impacted? How might those be streamlined?
32 Obviously that's not really in our purview, but again all these pieces have to fall into 33 place in order to deploy new capacity. And particularly if you are looking at 34 repowering an energy community, the timing matters. As Doug said, you don't want 35
19 to leave the people behind. So again, just for the NRC, staying connected with your 1
federal peers and making sure we understand how things need to line up if they are 2
to actually be successful in meeting some of those goals that were set out in the 3
ADVANCE Act.
4 Our other activities are more on the NRC regulatory side and so those have been 5
informing our interactions with the NRC already. We completed an assessment of the 6
NRCs environmental requirements for siting and we sent a summary of that 7
assessment. The NRC, you wouldn't be surprised to know, that's informed many of 8
our comments on the different draft regimes that you all have been putting out and 9
that we've been responding to some of that information will again show up in 10 comments on the new reactor impact statement and all that sort of thing.
11 So we've been collecting this information and we're now providing it through those 12 various avenues.
13 We similarly performed an assessment of NRC safety, citing requirements, and again 14 that also has sort of a piece in the new reactor GEIS, but it also appears in other 15 guidance areas and so we will continue to provide that input based on that 16 assessment. And then the last one I have on this slide is we did have two appendices 17 in particular in our July letter to NRC on regulation of rapid high volume deployable 18 reactors in remote applications or RIDRA.
19 And while in part that focuses really on the business model and the thinking behind 20 deploying lots and lots of micro reactors, as we do with everything we're trying to set 21 it up to be risk informed and performance based. So, there's really not a firm cut off 22 or a firm box around any technology. It's more so if your technology can 23 demonstrate this. Or your technology leverages that. Then you might be able to use 24 enhanced or more efficient processes. So, these particular appendices would have 25 some relevance here as well, and we'll go into a little bit of what those were about as 26 we get to the ongoing work. So, let's go to the next slide.
27 Some of those key findings again, just to reiterate on the state permits and the 28 federal interconnection, there are multiple processes that have to be looked at for 29 any project. They each have their own timelines, and they need to be managed in 30 parallel with the NRC reviews so timely cooperating agency determinations may 31 support the NRC and vice versa. Timely information from NRC on what you really 32 need from those agencies may also help in streamlining your own reviews.
33 From the assessment of the NRC environmental requirements for citing, we continue 34 to identify and emphasize opportunities to streamline things like the purpose and 35
20 need that is articulated and what does a successful purpose and need look like?
1 Alternative sites analysis, particularly if you're looking at coal to nuclear repowering 2
in a coal community or reusing some of that infrastructure? Alternative sites become 3
very interesting and Daniel will talk about that a little bit more because they did 4
some excellent technical work at EPRI to look at these things.
5 There's also opportunities to allow the use of an environmental assessment and 6
possibly even categorical exclusion. I will say congratulations to everyone involved 7
this week in the construction permit recently voted to be issued for Hermes 2.
8 That's an example of an environmental assessment being used and we think we can 9
continue to leverage those learnings in the areas of brownfields. On the assessment 10 for NRC safety, citing requirements, as I noted, opportunities to fully credit new 11 design features and using risk informants based review approaches.
12 Next slide.
13 So that brings me to the work in progress and as I promised, I would mention a little 14 bit more about what some of those appendices to the RIDRA document entailed.
15 They were looking at meteorological data collection and seismic hazard insight 16 characterization.
17 So we now have work in progress looking at what are some potential alternative 18 methodologies for meteorological data collection.
19 Alternative methodology for seismic hazard and site characterization.
20 As well as some work on going on population related, citing considerations which 21 has been considered recently by the NRC, and we think that more could be done in 22 that area.
23 So we'll go to the next slide and talk a little bit more about what we have in mind.
24 So on the meteorological data collection, of course, the ADVANCE Act calls for NRC 25 to consider the availability of historical site specific environmental data.
26 We know that in the NRC already has guidance on site specific meteorological data 27 collection and this guidance in Reg Guide 1.23 requires installation of an on-site 28 tower and that leads to additional time and capital costs.
29 And these are not minor costs - they are, you know, they are very real and very 30 significant. And again, when you think about the timing of the transition and 31 everything that goes into it. This is an area where we might be able to gain some 32 efficiencies.
33 As evidence of other work that NRC has done recently, of course there was the 34 recent rulemaking 10 CFR 50.160 on a performance-based framework for emergency 35
21 preparedness for small modular reactors and other new technologies, and we think 1
that we can build on that frame. As you know, another example of how we might be 2
able to streamline our data collection so we are developing an alternative 3
methodology and on the next slide. I will talk a little bit more about that.
4 So any methodology has a few steps. Some of these are kind of obvious.
5 Step one. Identify the sources that you could pull from and some examples there.
6 It could be a specific airport or other data source that was already required by a state 7
or local agency.
8 There could be an existing on site, meteorological tower and just because it wasn't 9
put in for the purposes of an NRC application doesn't mean it's not providing good 10 data that could be used.
11 You could also identify state specific climatic data summaries from National Centers 12 for Environmental Information.
13 There's guidance from the International Atomic Energy Agency, which may be 14 relevant, so we think there are a lot of different opportunities to identify appropriate 15 data sources.
16 Once you've identified them, then of course you have to obtain the data and when 17 you do that you might be looking at some representative data sets, wind speed, 18 direction, resolution, these types of things that are comparable to what's specified in 19 Reg Guide 1.23, but maybe not exactly what was specified in the guidance, so 20 thinking more about. The information that is necessary versus the information that 21 may currently be stated as required.
22 Let's see.
23 Oh, many of these data sets may already meet requirements specified by the user PA.
24 Again, they've been vetted by experts in the environmental sciences, so they're not 25 without merit. It's just a matter of making sure that they can fit the purpose that NRC 26 would need them. To fit, as I mentioned, airport data from the National Centers for 27 Environmental Information, which subjects data to detailed quality assurance and 28 quality control procedures before they're archived and made available to the public.
29 So this is readily available. And there are also opportunities to maybe leverage 30 National Weather Service information as well. The mesonets listed here.
31 Our state level networks of meteorological stations and again, these have grown 32 substantially in coverage since NRC regulatory guidance was first issued.
33 You might be able to find data at county or sub county level.
34 And our contractors shared with me that an example of that might be the State of 35
22 Oklahoma has quite a bit of information. So these stations often use research grade 1
instrumentation, which is similar to the specifications in Reg Guide 1.23.
2 So again, we will explore that some more and provide as part of our proposed 3
approach some detailed information on how that could be used.
4 But then finally, the last piece of any methodology is to perform those computations 5
that support the permitting and the licensing.
6 And these are, you know, the familiar computations that are already used today, 7
looking at atmospheric stability.
8 Looking at time averaged winds and other meteorological parameters.
9 Looking at everything that's required to go into considering and justifying an 10 emergency planning zone.
11 So we will of course include that information as part of our methodology as well.
12 I don't have on here, but I believe our anticipated timeline for having an alternate 13 methodology ready for the NRC is early next year. So, we're looking at first quarter 14 2025. And that will be right in line with our next slide and our next body of work, 15 which is the seismic hazard and site characterization work.
16 So, NRC has recently published a white paper with an approach to nth of a kind 17 micro reactor licensing and one of the items covered in there was the conceptual 18 approach for grading the level of site investigation and characterization. So we have 19 shamelessly duplicated that NRC flow chart here. Really, to highlight that again, while 20 this is in a paper on inference. The concepts may be very much the same for any new 21 technology, and any brownfield sites or areas where we're trying to get handle on a 22 lot of different sites that have a lot of things in common. It is also similar to the idea 23 of a site parameter envelope, which technology designers may create. So we've 24 heard a lot, especially with the new reactor generic environmental impact statement 25 about plant parameter envelope, right. If your plant fits in this box, it could go on this 26 site, but we could also be thinking about site parameter envelopes and saying 27 brownfield sites have all these things, and if you have a technology that can fit there 28
- we can match them up, so there are opportunities for brownfield sites to be 29 enveloped and we do see a parallel with this conceptual approach that the NRC has 30 outlined.
31 Next slide.
32 So considering all of that plus our earlier comments in our redraw proposal, we are 33 developing an alternative methodology for seismic hazard and site characterization.
34 We are of course producing comments on the nth of a kind white paper today, but 35
23 many of these comments will then be further fleshed out in this alternative 1
methodology that we propose and we're thinking of proposing. That there's 2
sufficient margin on the site margin parameter or the exclusion area. Boundary dose 3
margin which could justify reduced site characterization. Proposing that minimal site 4
characterization for seismic hazard could rely heavily on the US Geologic survey, 5
national Seismic Hazard module, as opposed to a purely site specific senior seismic 6
Hazard Analysis Committee process. And that is aligned with our proposal paper.
7 And again, this time we're looking at submitting in 2Q25 so probably right on the 8
heels of the meteorological tower work. And my colleague John Facemeyer is sort of 9
leading the charge on both of these. So yeah, happy to connect you with him. If 10 there are any additional questions there.
11 Also, let's see. I want to point out that the ADVANCE Act also discusses considering 12 standard materials that are in compliance with existing codes and standards, and so 13 this is another area where there are ASCE standards and there are other international 14 standards. So, trying to pull all of these together and see what we can leverage to 15 streamline the process for efficient and effective review.
16 Next slide.
17 I'll talk a little bit about population-related siting considerations. So, as I said, the 18 NRC has done some work on this recently and in fact just updated the regulatory 19 guidance in regards to Reg Guide 4.7. But still, even with those updates, it may 20 challenge the business case for widespread advanced reactor, especially micro 21 reactor deployment. And we see that the NRC requirements may still be overly 22 restrictive compared to the accepted level of protection. Provided by requirements 23 for existing large light water reactors. So, we're going to look at the regulatory 24 history and the bases for really providing some alternative approaches so that 25 population citing criteria do not unduly limit widespread advanced reactor 26 deployment, and we really want to support facilities citing applications and decisions.
27 We're going to look at whether population is a factor in citing truly serves an 28 independent purpose. Whether that might lead to some modifications of the part 29 100 requirements.
30 We're going to look at population density distances and how those can be 31 commensurate with the characteristics of advanced reactors? Looking more 32 holistically at all of those characteristics and then really looking at, OK, what about 33 population centers right now, the NRC would not allow for citing in population 34 centers greater than 25,000 people. Of course, there's always room for exemptions, 35
24 but we know that exemptions are not always the most efficient way to deal with 1
things. And as we think about the potentially hundreds of brownfield sites that may 2
be interested in deploying new nuclear we think that this is an area that may need to 3
be revisited. So, if we go to the next slide.
4 And do one more click.
5 That's OK. There's going to be more. But for now. Stop right here, OK?
6 So like I said, why it matters.
7 Christine discussed the reports that DOE had issued previously, and they found more 8
than 300 existing and recently retired coal sites that are suitable to host advanced 9
nuclear. And those would of course employ the same or perhaps more people than 10 the coal facility they would create long term jobs. In those host communities, 11 increasing the total income and increasing the revenue for the host communities, the 12 power plant operators and the local suppliers. But DOE worked with the specific 13 requirements that NRC states today.
14 So if we do another click.
15 There are about 80% of U.S. coal communities that are greater than 25,000 people 16 today. So, this as many as 300 existing retired coal plants that are suitable to host 17 advanced nuclear. It's just one fifth of the population of coal facilities out there that 18 may ultimately want to think about nuclear. So again, exemptions if needed, as they 19 come up, may work for now, but eventually, as we think about streamlining the 20 process and making sure that all of these pieces can come together in the right time 21 frame. And making sure that those who are not intimately familiar with NRC 22 processes know what's really a deal breaker and what's just, we'll need a little more 23 information. This becomes very important.
24 Next slide.
25 OK.
26 So things that we think NRC could look at as you're going through this portion of the 27 ADVANCE Act, certainly revising guidance and regulations as needed to 28 acknowledge that brownfield sites are already impacted and site reuse may be an 29 environmentally preferable.
30 Alternative to additional land disturbance - brownfield site review should not be 31 more resource intensive than Greenfield site review. And existing information to 32 brownfield sites may be equivalent to what in our CD - it's going back to Doug's 33 point on equivalency.
34
25 Also, NRC activities to respond to the ADVANCE Act direction should align with the 1
opportunities that are identified in the recent SECY0-24-0046. On implementation of 2
the Fiscal Responsibility Act of 2023 and I think you alluded to that when you were 3
talking about other NEPA requirements and other legislation that has recently come 4
through, so we noted that the staff recommends rulemaking to allow increased use 5
of environmental assessments. Applicant preparation of draft environmental 6
assessments, environmental impact statements, more narrowly focused need 7
statements and alternatives analysis and we would agree that those are all 8
opportunities for increased efficiencies. And then the final one here is again going 9
back to those. Folks who maybe don't know what are all the relevant regulations?
10 What are the regulations? What do they mean? What's changeable?
11 What's not changeable? You know what? Can I just add a few sentences in my 12 application versus forget about it, go look elsewhere. Perhaps the NRC could provide 13 clear summary position or guidance on what makes a Brownfield site viable for 14 nuclear. Part of that could also be what does the NRC not look at? Because EPA is 15 responsible for that, or the state agency is responsible for that. So just again 16 clarifying what your role is and what you're looking at and how folks can interact.
17 Thank you.
18 19 Sarah Lopas: Thank you. Alright. A minute here. So next we're going to go to the 20 electric Power Research Institute.
21 So we have Daniel Klein here.
22 Daniel is the principal team lead for nuclear beyond electricity advanced nuclear 23 technology at EPRI.
24 25 Daniel Kline: Alright. OK. I think we're up and running. Yes, OK.
26 Very good. Yeah. So, my name is Daniel Klein.
27 I work for the Electric Power Research Institute, so we are non for profit organization 28 and we conduct research in all forms of electricity generation, transmission, 29 distribution.
30 I work in the Advanced Nuclear Technology Program and as Sarah said, I lead the 31 Nuclear Beyond Electricity Initiative.
32 So today here. Going to talk about practical guides that were basically generated and 33 then prepared for the power resource planners, owner and operators of coal sites, 34 and for site development and nuclear deployment. So next slide please.
35
26 So we created a series of brownfield and coal repurposing documents.
1 So the first two bullets that you see on the slides on our site selection guides. So we 2
have one site selection guide for a large region of interest. And then what is more 3
applicable here as we talk about brownfield and v repurposing that is a single site 4
evaluation guide. That that is a document. If you have a targeted site that you have in 5
in mind that you can basically evaluate that side for nuclear deployment and in the in 6
the next slides, I will talk a little bit more about what's the processes. But this is a 7
practical guide that that helps the developers to step through and see that side is 8
suitable for nuclear deployment.
9 The other report that I want to point out that is the first from the group of so-called 10 repurposing series that is our coal to nuclear guide. A lot of that again is applicable.
11 For Brownfield, it was written mainly for coal repurposing, but as you step through 12 that, 90% is applicable for brownfields applications and consideration in general.
13 Next slide please.
14 So this is the EPRI coal to nuclear guide that I mentioned.
15 So that report was written and is structured really as a practical guide, so you can 16 take that document and if you are not very familiar, super familiar with nuclear 17 technologies that that you can read it and understand it gives good references to 18 applications in the NRC process and then requirements.
19 And it was written like I said, for power and resource planners, owner and operators 20 of coal sites. Again, that are not inherently familiar with this nuclear. Colocation 21 deployments. So, this is the whole purpose and that document is really a very good 22 starting point. If you investigate coal to nuclear repurposing. And again, this can be 23 very much applied for all brownfield science.
24 So and I think the slides will distribute it.
25 So there is on the right side you see the document number. You can pull that 26 document from the EPRI web page and then then you can look through that.
27 Next slide please.
28 So, as Allen and Sarah mentioned already, a lot of the benefits when it comes to 29 benefits reusing coal sites or brownfield sites that that is in line with what we have in 30 our found in our research.
31 So here we see also that existing grid transmission infrastructure interconnection can 32 be can be reused.
33 There's advantage that you have access to the large borderless draw and water 34 discharge allowances already, so you can leverage that and then the sites they have 35
27 typically well-developed transportation infrastructure way of access to railroad rail 1
right-of-ways so that that can be leveraged. Then the existing environmental permits.
2 We basically lay out some permits that can be leveraged that we typically see for 3
nuclear applications, so they can be used or modified as needed.
4 But you have a really good starting point and that will all help us streamlining the 5
permitting process, right?
6 We'll take advantage of what you have. Same for existing buildings. Site equipment 7
that can be used. For nuclear reactors as much as you had it used for storage, 8
basically. For your coal facility or other industrial facility and then as Doug 9
mentioned, repurposing of the available workforce, right?
10 I think Doug mentioned 74% of the skill set can be used.
11 And yeah, we see same thing.
12 So you can leverage the skilled labor, for example technicians that you have.
13 And that the people can basically stay in that area.
14 They don't have to move to with their families, you know, that's their home, basically.
15 Take advantage of that and the bottom line here is when you take advantage of 16 these potential benefits, it can lower the cost and facilitate a faster return.
17 On the next slide - we also see some challenges, right?
18 It's not like many other things in life. Not everything's just positive.
19 So and again, we see very much similar topics that were mentioned today. One can 20 be the site remedy, right, that you have to consider.
21 Potential costs associated with environmental cleanup activities.
22 We heard about heavy metals, hydrocarbons or chemical spills.
23 That have to be looked at and considered before we can deploy a nuclear facility or 24 their acceptable limits. So, then assessment of structural foundation and buried parts.
25 A lot of facilities have buried parts. It can be for cooling, water intake, etc. So, as we 26 consider a lot of what is aboveground, we also want to consider what is below 27 ground. That is an important factor making sure that you still have structural 28 integrity. That you need for the parts and then basically projecting out years where 29 you're going to use that equipment because all that existing equipment has some 30 lifetime on it, right? The bullet here on that slide. That that is a labor needs as you 31 transition from a potential decommissioning to a new construction and operation.
32 So we just want to stress that you need various levels of skills and the craft that is out 33 there seem to be willing and interested to cross train, but that also is a commitment 34 from their end. You know, they have to be willing to do that and based on the 35
28 positive interaction as a community, it sounds like that.
1 But that's OK. This is your contribution.
2 You have to be willing to get cross trained for some of the labor or skills that we 3
need. Yeah. Then you touched on the security requirements, right?
4 We recognize like nuclear facilities have stricter security requirements that have to be 5
considered as we transition from a brownfield to a future nuclear facility.
6 So all that requires careful planning, the resources that you require for that and it's 7
strategic approach that you have to apply. Again, going back to the document to 8
help you and then guide you through these processes that you can basically use it 9
like a guideline check box approach where you walk your way from top to bottom, 10 making sure that you do these things, and that that will really help facilitate the 11 process and assessment.
12 Alright, next slide please.
13 OK, here this is a high level overview of the process.
14 So going from top to bottom right. So, it starts of course with a site identification 15 that we look at from a greenfield side, we leverage site characterization information 16 and then it comes to technology and then design selection of the nuclear power 17 plant, right. As we know small modular advanced reactors come in various sizes.
18 Now when it comes to electric output, the MW electric so that you typically want to 19 match an electric output, especially when you think about leveraging the switch on 20 transmission systems that you find a technology that that matches the electric output 21 to watch what you had before and that, for example, look at the amount of water 22 that you would need for cooling purposes, et cetera. And then you can step through 23 what we touched on site infrastructure.
24 Existing assets leveraging the permits that you have available in other cost and 25 economic evaluation and you see on the bottom what it shown in pinkish color or 26 that is that community outreach as you start basically from considering.
27 Where we do a brownfield conversion to nuclear, have that community involvement.
28 Then the next slide please.
29 This is again from their own siting guides, we identified 11 criteria as an initial high 30 level screening for assessing of that brownfield or former coal site could be a good 31 match for nuclear deployment. And again, this is in the list, so you can walk your way 32 from top to bottom. And then you can look at, OK, what did we have on geology and 33 then seismic? Cooling water requirements and then supply. Am I in a flooding area?
34 You know, that can be often a showstopper. Nearby hazardous land uses population 35
29 requirements. Kati touched on atmospheric dispersion, groundwater, radon, nuclear 1
pathways, disruption of important species, habitats, plant sites, wetlands, land use, 2
and then the last one - pumping distance. It's more like an economic financial aspect 3
but typically, if there was a coal site before, the pumping distance should be 4
acceptable for a nuclear unless you really have to move that nuclear plant further 5
away. You're still on the coal side, but a lot of way of farther away from the body of 6
water. But again, this just completes the list. That's why we have that listed there.
7 And on the next slide, please.
8 This is just a list of state requirements or permits for nuclear power plant 9
construction and operation. And see what a coal site has available that that can be 10 leveraged there. For example, there's a State Department of Environmental Quality.
11 Again, there they have some permits for clean air from the Clean Air Act, drinking 12 water. Groundwater. Pollution discharge, solid waste and so on.
13 We also list here the State Department of Transportation that is the transport of 14 hazardous material, a radioactive material. So, these typical nuclear-geared 15 requirements and then permits. But again, this is a list. You can leverage what a coal 16 site may have. Outside of the radioactive material permits, but you can leverage and 17 it also goes back to faster permitting and deployment schedule at the end of the day.
18 Next slide please. Yeah. So, Allen touched also on the consideration for reusing what 19 I call secondary side equipment. Basically, the steam cycle equipment, right.
20 Next slide please.
21 So here, here are a couple things and that that was mentioned also when it comes to 22 the design points, right? So that looking at a coal facility, they had a certain mass 23 flow rate pressure temperature for the steam. Now when I think about deploying a 24 nuclear power plant and basically hook up my N triple S system to an existing 25 secondary site from a coal plant -these design points have to match.
26 Otherwise, it's most likely a non-starter.
27 There's also remaining design lifetime, right?
28 So if you had a coal site that you retired while you had many years of runtime on it, 29 so is that even worse? Considering using the turbine, the condenser etcetera or is 30 that equipment aged and there's not enough life left in that equipment that that you 31 want to go down that path?
32 And then jumping back up to the second bullet here, we talked about a little bit 33 quality requirements, yeah, and the nuclear side as we know, we can have systems 34 structures and components that can have a higher level of quality requirement 35
30
- augmented quality that that a coal plant Rankine cycle steam supply system may 1
not have. OK. So again, these are saying that you want to look at. But there's a 2
positive that the last bullet on the slide here where there was some DV study that 3
had been performed and 15 to 35% could be saved on overnight capital. If you find a 4
matching case, you know where you have an N triple S that might work with a 5
secondary site of a former coal plant, assuming there's enough of a, let's say, design 6
compatibility. And the lifetime of the secondary site looks acceptable - it could be 7
used in reality.
8 It might be more unrealistic that you'll find a good match, but since the topic came 9
up we created a slide to mention that and basically for awareness.
10 And the last slide.
11 That is a general approach of separation of nuclear and a non-nuclear facilities and 12 on the right side you see the document that we created that's called the technical 13 methodology to demonstrate the separation of nuclear facilities from adjacent 14 facilities. EPRI also created a topical report that had been submitted. And then that 15 basically talks about that you have your nuclear site, the N triple S, the nuclear steam 16 supply system as a safety-related system and then basically everything outside of the 17 steam generators, steam conversions are the steam cycle that these are non-safety 18 related components for the balloon part of the balance of plant and we see others, 19 like Terra power, for example, in the in the Natrium technology, they have the same 20 concept as potent cold tank in the nuclear portion and then basically there's a 21 decoupled conversion cycle for electricity generation.
22 So that's what I had prepared today.
23 So hope that that helped a little bit understand what we have from the practical 24 guides as we hear a lot of things to do. But here's like a basically cookbook that you 25 can follow as you think about nuclear deployment at the Brownfield site.
26 Thank you very much.
27 28 Sarah Lopas: Alright, I'm going to play around here a little bit everybody, just so I 29 can get my screen up and running for people here in the room. Let me look at our 30 agenda here. We're pretty much right on time. I love it.
31 So we're going to go until about 2:50 p.m. with a panel discussion here.
32 I do want to encourage folks NRC folks that may be out there out there virtually and 33 any other panelists that are with us today virtually.
34
31 You know, we're going to use the raise hand function, so just raise your hand and 1
you're able to unmute yourself, and we're just going to get right into it.
2 3
So, I don't know if you want to start in the room with questions.
4 Yeah, go ahead, Milton, and just introduce yourself for everybody. When you ask 5
your question or make your comment.
6 7
Milton Valentine: Sure, Milton Valentine. I am the chief for the Containment and 8
Plant Systems Branch and my team is looking into the reuse of steam cycle ultimate 9
heat sync components and were glad to see that someone has taken a look into the 10 potential challenges that it represents to reuse the existing structure, systems and 11 components at the site.
12 We certainly see the potential in leveraging these existing structures, but we also 13 want to make sure that everyone understands that there is a pedigree that is 14 expected pending on the use of these structures. To be combined with these new 15 technologies, it's not black or white. There's, there's a lot of gray that should be 16 looked into, and I appreciate also the presentation that Kati and I'm going to butcher 17 your last name - Austgen - facilitated earlier about looking at, you know, the site 18 characterization cause all of these goals go together right, how these structures were 19 designed, what's information that was used to come up with what they have already 20 on site? But it is important to understand how functions, how are these going to 21 withstand the expected loads and the conditions for safe operation? So, it would be 22 great to perhaps take a closer look at what can be done to make sure that we have a 23 process in place to help potential applicants understand how they could come up 24 with this information so that we can just make it easier when it's time to do to do the 25 review. Its an important piece of information that will be looking forward to getting 26 from applicants.
27 28 Kati Austgen: Yeah. OK. That's a good comment to have come up with basically a 29 guidance document to assess existing SSCs if they are suitable for nuclear 30 deployment. If you can match them right that that is what you're what you're saying.
31 Yeah, it would be something to think about.
32 33 Milton Valentine: Yeah, I'm sure there's there are. There could be other 34 recommendations. My staff, the actual experts on this topic, are online and I invite 35
32 them if they have any comments or questions on those.
1 Please raise your hand. But I just want to make sure that you all hear from us that this 2
is something that we will be looking forward to understand further, OK.
3 4
Allen Fetter: So, following up on that, I appreciate you tailoring your presentation, 5
Daniel, to address like the secondary side and I heard it sounded like you were 6
almost dusting off some earlier stuff on reusing secondary systems. And regarding 7
that you said you identified cost savings. Is this something that people are still 8
looking seriously at? I know you gave a pretty good synopsis of what would need to 9
be looked at, but does that 15 to 35% still hold or is that something that needs to be 10 looked at again?
11 12 Daniel Klein: That came actually out over the report, and we mentioned that in in 13 my slide when you go back, I had a there's a report that's called Study of Key Cost 14 Drivers and Solutions for Nuclear Power Plant BOP Construction and then that is 15 where that information is from. At this point we do not have ongoing research in that 16 area as far as I'm aware of, but as mentioned, if there is an interest then this can be 17 looked at closer and we believe there is enough of our substance that this is real.
18 19 Christine Palmer King: Yeah. So, in our 2022 and the DOE 2022 work along with 20 citing a techno economic analysis was done. That's where that 15 to 35% overnight 21 capital cost gets quoted.
22 Oregon National Labs led that work. And you know, they have a model.
23 A significant amount of that cost savings is from the reuse of your transmission and 24 substation. And those types of large - they have categorized those costs.
25 So if you want to get into the details, but. I think before we do new work, we should 26 look at what has already been completed in that space.
27 28 Gordon Curran: Yes, I'm Gordon Curran. I work for the containment systems branch, 29 which is Milton's branch that he was just talking about. Yeah, use of the existing 30 components.
31 I believe what he was trying to say it has if you reuse the safety or a component for a 32 nuclear power plant that that it's a safety related component. There's a much higher 33 pedigree than there would be I would assume at a coal plant. There's a major 34 qualification program that you would have to put the components through and I'm 35
33 talking components. I'm talking like pumps and mechanical components, so use of 1
those would be very, very challenging. Now I could see maybe the use of those 2
components if the designer decided that they they're adequate for some non-safety 3
then. That might be possible, but that would be up to the designer to determine that 4
based on like you said, the life of the life of the components itself and the sizing or 5
what not? For that, so I just, I just wanted to point that out.
6 7
Christine Palmer King: Yeah. Thanks Gordon. I think just to be clear, so the I would 8
say the primary focus would be when you consider reusing structures, system 9
structures and components would be for non-safety-related applications and it 10 would be really a stretch goal. I would say if you try to use a commercial equipment 11 from a coal or whatever site for nuclear safety-related application, because we know 12 all the work that goes in just to fabricating that component that you absolutely 13 wouldn't have, you know. So yes, it it's fully understood. What you're saying and we 14 fully agree to that. Yeah. And like you mentioned very well, like it's all dependent on 15 the characteristics of the design that is selected like in, in our mind looking at 16 operating sites, the numbers are very different from what this new advanced not like 17 what reactors could be. So, it depends. It's any I hate giving that answer, but it will 18 depend. And we look forward to having those discussions when the time comes, 19 yeah.
20 21 Daniel Klein: And you probably go back to what Christine was saying? There might 22 be more value if looking like electrical components, etcetera, not necessarily fluid 23 systems you know. Thank you.
24 25 Christine Palmer King: And I think I think there could also be decisions that are 26 made that. Prior to getting to this point of choosing to reuse. If you are, if you look at 27 the way integrated resource plans are put together. Especially in the face of growing 28 demand. Would a utility really be able to take a coal station offline and have a gap in 29 their generation without having it replaced, right? So, I think you know it may be that 30 things happen in the integrated resource planning process. As well as an obligation 31 or a desire to maintain jobs which I know, Sarah, that's something we want to talk 32 about at a future meeting. But those types of decisions could also have you making a 33 decision of being adjacent to which might make it or a few miles away or nearby or 34 something like that, which also makes using fluid systems very challenging.
35
34 So there might be business decisions made ahead of this that, you know that that 1
make reusing the secondary side not a viable path or I think what Daniel said is 2
maybe not very realistic.
3 4
Daniel Klein: Yeah. I think primarily a lot of the value in the way I kind of visualize is 5
if you have a fence line at the plant, there's all the to use a technical term that goes 6
ins and that goes out. So that you know the transmission, the, the sewage, the 7
water, the rail spurs and you know the sort of soft permits that are already in place as 8
an aspect of operation and then anything inside the fence being sort of the clear 9
slate. Where you know you would go to build your project.
10 11 Sarah Lopas: Any folks in the room with additional questions, topics of conversation 12 here? And I want to encourage NRC staff who are online and listening. You have 13 some good resources here. Now's your chance, because you have to write me a 14 report very soon! If that doesn't sound too threatening. If you don't have any 15 immediate hands that I'm looking right now, Kati, I may go to you. And I kind of 16 really like the idea of when you mentioned some sort of guidance about what the 17 NRC doesn't look at for a Brownfield site. So, I'm wondering how much you know 18 when you were talking about kind of clean up requirements and working with the 19 States and things like that. How far have you gotten into that in your in your work 20 and this can go to anybody - Christine and Doug, too. I mean, has there been a lot of 21 discussion about clean up requirements by specific states? Are there, you said you 22 looked at 5 states?
23 Kind of their requirements, and there's some states that are a little bit easier. I mean 24 what I'm just so curious about kind of the remediation aspect. Cause I'm struggling 25 that with, I'll be honest, I'm struggling with that a little bit from an environmental 26 standpoint, kind of looking at some of the public health issues and things like that.
27 28 Kati Austgen: Yeah. So, we actually did not look generically, at the site remediation.
29 We treated it more as, uh, clearly it's got to be clean enough that from a business 30 perspective, particularly if you're not the owner of the coal facility, right, you are 31 willing to come in and put another facility in place. So we did look more at things 32 like, OK, you know the current facility needed a discharge permit or the current 33 facility needed access to some amount of water. You know, would the nuclear facility 34 coming in need the same or less water and therefore how likely is it that you could 35
35 just go to the state and say I'll be replacing this facility and as soon as it goes offline, 1
this one will come online and use the same thing. So, we did not look at that as 2
much again. You know, we know from utilities who are familiar with working with 3
NRC because they're already licensees we know. What you look at and what different 4
agencies look at. But again, those who are not familiar with NRC probably have a lot 5
of questions. Well, what is NRC going to require me to do about this, that or the 6
other? And so, you know, again, even if it's a summary position or you know high-7 level document that says the NRC perspective, we will assume XYZ, yeah. And then 8
we will look at ABC. Yup.
9 10 Sarah Lopas: OK. Other panel questions comments NRC staff? Gordon, go for it.
11 You'll take us out of here, OK?
12 13 Gordon Curran: Yeah, I have a question for, I think it was Kati from NEI that said 14 indicator on one of their slides that they're putting or they're working on a safety 15 siting document, where they're going to credit new design features, but it didn't have 16 an ML number, so it's something that I think that you're working on. What is going to 17 be in that report or what are you looking at specifically? Can you elaborate on that?
18 19 Kati Austgen: Yeah, yeah. So that is complete. It is not public. It is our compilation of 20 everything that NRC requires from the safety aspect of siting whether it's through 21 regulation or whether it's through guidance that says this is a way to do it. And you 22 know, sort of by default, everyone has just followed that one set of guidance. But in 23 many cases, that guidance, if not of course the rules themselves were created.
24 Thinking about large light water reactors. So, they're not thinking about the different 25 features that are now in the various new designs. And so, sort of highlighting for 26 ourselves first and foremost, if you're doing a near term application - what is ripe for 27 justifying? I've got a different way to meet that intent, but then also as we're going 28 through this modernization of requirements and guidance, what is ripe for changing 29 because hey, this could apply to everybody if we tweaked these few little things. That 30 was one of the areas where I mentioned that we're using all that information we 31 pulled together to inform our comments on various NRC guidance documents as 32 they're coming out. So again, if there's a specific piece of the ADVANCE Act where 33 some of that information we pulled together is relevant, then we would provide that 34 feedback and say, hey, we noticed, you know guidance, this, that or the other could 35
36 be more broadly applicable or could consider Brownfield sites if you changed this.
1 Sam, did you have the question? Yeah. So, there may be others actually.
2 3
Gordon Curran: Thank you.
4 5
Sarah Lopas: I've got two, so we'll do you and then we'll do Tony and Don and then 6
we'll go break.
7 8
Sam Lee: Quick question for Kati. So, when you talked about and I think you were 9
quoting DOE study, mm hmm, where they found greater than 300 use existing and 10 retired coal plants suitable to those in advance. And you said 80% are in 11 communities greater than 25,000. So does the 300 represent the 20% that are in 12 under 25000 or is the 300 the total there so it could be 1500? And then I have a 13 second OK a follow up question that might be a little harder to answer.
14 15 Kati Austgen: Yeah. I will let Christine Double check my numbers here. Yeah, I 16 believe the 300 fits within that community's less than 25,000, OK. Is that right, 17 Christine? Because you were looking strictly at what NRC requirements are and NRC 18 requirements said not within a population center greater than 25,000.
19 20 Christine Palmer King: Yeah. So actually, when we started this study, the majority of 21 the locations screened out because of population density. In terms of large or the in 22 terms of amenability for large light water reactor was we were not - we were working 23 with existing transmission. So, in some cases you may have enough water to place a 24 large light water reactor, but it would require upgrade to transmission. So, we were 25 not trying to do that kind of math in this first assessment. So, you may have sites that 26 are quoted to only be amenable for small modular reactors, but there's enough 27 water in there if you upgraded transmission, you could site a large light water 28 reactor. So yeah, that study, it's important to look at, you know, one we were working 29 also with criteria that we could envision on a GIS-enabled tool. So, and we'd be 30 happy to talk more about the details behind that that screening. But Kati's right it it's 31 the 300 is after the population screening.
32 33 Sam Lee: OK. Great. Second part of my question and I don't know if you have an 34 answer to this is that did you or have you considered maybe doing a polling to sort 35
37 of see how many of those 300 you know demonstrated interest or curiosity to 1
pursue. You know an advanced reactor or you know another, you know nuclear 2
reactor.
3 4
Kati Austgen: In that way we have not done any of that.
5 6
Christine Palmer King: So we made, we did have a pathway by which folks that were 7
affiliated with the station, whether it was the utility or community leadership or state 8
level legislators, they could get the information. From that DOE report about their we 9
did not publish names publicly. The DOE is not here to tell you that nuclear is right 10 for you.
11 Tell you we had a significant interest in in getting the information on those individual 12 sites. And we've provided a lot of that information out to the community.
13 So there has been a significant response and interest from the communities that 14 have these coal stations.
15 16 Sarah Lopas: Thank you.
17 All right, let's do just two more questions quickly. Tony, go ahead, Tony.
18 19 Anthony Dimitriadis: Oh, thank you, Sarah. Good afternoon.
20 I don't have a question. Actually, I have a couple comments.
21 My name is Anthony Dimitriades.
22 I'm the branch chief in Region 1 that's near Philadelphia for NRC and I'm responsible 23 for inspections at operating sites - nuclear sites that focus on radiation protection 24 programs. I have two other business lines that I'm responsible for. The other one is 25 spent fuel storage. That is the spent fuel that is used at nuclear reactors. That's 26 encased in canisters, very heavy, very robust. And the third one and the focus of this 27 is decommissioning and my area of inspections goes from Maine to Florida, the 28 eastern seaboard, and we have a lot of decommissioning sites, namely 9 nuclear sites 29 and some complex material sites. My comments really have to do with number one 30 in that in support of the ADVANCE Act, if there are, if there is interest in any of these, 31 we have decommissioning reports that are available to the public so that anyone can 32 see these reports - so that they can see what it is that we do and what it means to 33 have an affected and an impacted and unimpacted area. So that's number one and 34 number two is that that's really important is that if you if you have questions, please 35
38 don't treat the NRC like a black box - engage us. We engage with the industry, with 1
our licensees, with our Region 1 users group - and call us. You know where you can 2
find us on the web and call me and you know we can arrange to have discussions so 3
that we can support that. If you have questions to really advance the ADVANCE act, 4
that's all I had.
5 6
Sarah Lopas: I like it. Thank you, Tony.
7 Alright, Don, you were going to take us into break, so keep that in mind.
8 9
Donald Palmrose: Yeah. So, I'm just kind of looking for information cause I 10 remember earlier was mentioned about that the coal plants have existing monitoring 11 programs. So I was wondering if any of the reports that any of the groups have 12 generated for those monitoring programs what are they and how do they compare 13 to the NRC monitoring programs, in particular the meteorology meteorological 14 instrumentation and like that, how that would compare to what we would require in 15 the Met Tower.
16 So if you can just point, you know can pass on the break, the point out that if you 17 have any of those documents that were provided, you know or listed in presentations 18 have that information. I think that'd be helpful, especially for like our groundwater 19 people.
20 21 Kati Austgen: So I will let Christine and Doug speak to what might already be in 22 their case studies. But I will say as a general level that kind of information will be 23 included in the alternative methodology that we're developing for proposal. So we 24 don't have that information well characterized yet, but it is one of the things that we 25 would look to identify as part of that methodology.
26 27 Christine Palmer King: I would point to the Natrium project. I think they are the 28 furthest along in terms of the comparison of meteorological data. I know that was 29 something that they started a couple years ago. And I'll leave it to Doug to talk about 30 what we found in terms of groundwater monitoring already existing. Not sure how 31 we documented that.
32 Umm, in the citing studies that we did.
33 34 Doug Hardtmayer: Right, yeah. And so, we did not take a thorough scrub to do an 35
39 A-B comparison against what the coal stations doing versus what a new plant would 1
do. But with the current coal stations and just the status of some of the CCR ponds 2
and things like that, some locations will be required to put in groundwater 3
monitoring just to check you know that the status of those combustion residuals and 4
ensure that everything is above board there. So, it is site to site dependent but it 5
could be a source of data to be leveraged.
6 7
Christine Palmer King: I would also I guess maybe kick it over to Daniel Klein. I think 8
while maybe not in the nuclear sector, certainly the generation sector of EPRI has a 9
significant amount of information about the remediation of coal sites and then also 10 how they're monitored that might be there. Might be some information they have. I 11 don't know if they've done a crosswalk as of yet, but they could tell you, at least 12 potentially tell you what exists today. In terms of monitoring things at coal sites.
13 14 Daniel Klein: We'll look into this because this is the other side of the house, OK?
15 So I have to find out what they have done eventually and how that is that potentially 16 cross map or not.
17 18 Sarah Lopas: OK. Yeah. And. And just as a reminder, we're going to have a second 19 panel discussion after the next group of speakers. So, we'll have other opportunities 20 for people who want to speak then, but it's we're a little past our time. So, it's 3:02.
21 Let's come back at 3:12, please. 10 minutes to take a break.
22 Get some snacks in here. I apologize for members of the public that have a hand 23 raised. I'm going to lower your hand.
24 We will have public comment after the second panel discussion.
25 All right. So that will be your opportunity.
26 So all right, we'll be back at 3:12 on the dot.
27 28 (BREAK - 3:02 - 3:12 p.m. EST) 29 30 Sarah Lopas: Alright, so Chris Nolan is our vice, the vice president of new Nuclear 31 generation strategy and regulatory engagement at Duke Energy. So, Chris is going to 32 talk to us today for a little while.
33 Thank you, Chris.
34 Let's turn it over to you.
35
40 1
Chris Nolan: First of all, I'd like to first of all, I'd like to thank you for the invitation to 2
speak. I think this effort's very important.
3 I'm going to have a few targeted comments that that reinforce some of the points 4
made by my colleagues speaking from Department of Energy, Nuclear Energy 5
Institute, and Electric Power Research Institute.
6 I think I'm going to pose some questions and give some real world examples that 7
hopefully will cause the staff to think about this issue more broadly and really to 8
maximize gain and benefit from this relook some of the opening comments were 9
more focused on incremental improvements and focused on things like 10 contamination and I'll give you our perspectives since we've done a relatively 11 extensive siting study for our service territory For our efforts in the road ahead and 12 deploying new nuclear.
13 So the first question I'll ask the staff is, is how can we get a more efficient review if 14 we have more information and the example I'll use is the license that the staff 15 recently issued at the Williams States Lee III Nuclear Power Station.
16 So it's a relatively contemporary example and many will not know that that is also the 17 site of the former Cherokee Nuclear Power station that Duke had a construction 18 permit granted by the staff in the 70s and worked on that plant until the project was 19 abandoned in the middle 80s and so this the state of abandonment, the unit one was 20 constructed down to bedrock. The containment base mat was constructed. The aux 21 building basement was constructed. The turbine island basement was constructed, 22 and about 2/3 of the containment structure was erected.
23 The Unit 2 excavation was down to bedrock. The Unit 3 excavation was down to soft 24 rock. And so was the Make Up A pond. A reservoir was built. The B reservoir was built 25 and the project was abandoned and left that way in the middle 80s, Duke sold the 26 property. When we were looking at building 2 AP 1000 units at that site, we 27 reacquired the property. We tore the containment down. The containment is 28 somewhat famous. It was used for the movie The Abyss to create the large tank of 29 sunlight-less water for the film. But we use the containment to re-riprap the existing 30 ponds, we use the, the, the rebar and recycled it and we prepared that site for 31 redeployment. We submitted the ER as part of the license and what we found was 32 that is that it would have been easier from an environmental perspective to build it a 33 Greenfield site.
34 And that that should be shocking because we left the site in a much better place 35
41 than we found it. But what we saw was we had a construction permit that the staff 1
reviewed and we paid for those review hours. We issued a new ER that the staff 2
reviewed, we paid for those hours, of course, but then we got questions about the 3
differences between the construction permit and the ER associated with the COLA.
4 So, we had more data, we had more certainty. There was a lot of intellectual curiosity.
5 You know, building at that same site made a lot of sense from the community and 6
also from the environmental impact standpoint. Since the site had already been 7
disturbed.
8 But there was no benefit realized from that in the review.
9 And so if you're talking about Brownfield sites, you're going to be talking about 10 more information and in this situation, the information came with an NRC pedigree, 11 right? It had a QA program. We had to build a new met tower. Couldn't use the old 12 met data because the standards had changed over time with the heights of the 13 instruments.
14 But when you embark on this effort, think about how more information could lead to 15 more efficient reviews.
16 Rather than more certainty in the determination because you have more data.
17 So that's a real-world experience.
18 19 The second question I would ask is and I'll pause at the end for all the questions that 20 you have. The second question I would ask is what does a Brownfield site look like to 21 the NRC? And I'll explain what a Brownfield site looks like to Duke Energy and it's 22 probably a little bit different, but I don't think the benefits are diminished in any way.
23 So we have announced that we have selected a site for our next nuclear deployment.
24 It's a coal to nuclear site. Christine King has done a lot of work along with her 25 organization in that area because it makes a lot of sense.
26 Our engineers were smart in the 70s when they picked the site for the Belews Creek 27 Steam Station, which is a 2-unit 2200 MW coal facility that's slated for retirement in 28 the mid 2030's and we plan to deploy new nuclear, following the retirement of that 29 plant.
30 So what are we going to reuse?
31 We'll reuse the water resource cause that's very important. The transmission resource 32 so we won't impact that environmental impact of having to make a new transmission 33 corridor.
34 We'll probably reuse portions of the switchyard so we can tie the plant in and have a 35
42 make-before-break concept with the coal plant, the workers will have a career path 1
as they transition from one site to the other without having to move their families.
2 About 17% of the tax base for the community. And the community will be made 3
whole as we transition from one generation type to another.
4 We're going to locate the new nuclear plants adjacent to the existing site, so we're 5
not going to reuse any of the secondary equipment.
6 We're not going to build over top of the existing disturbed land to us. That doesn't 7
make a lot of sense for a couple of reasons.
8 One is, if you're going to invest that much money on a nuclear power plant, I want 9
the secondary side equipment to be new.
10 Another is if we're going to make the community whole, we're going to operate the 11 coal plant up until the point where the nuclear generation station takes over.
12 So we have to be able to coexist and from a security and a construction standpoint, 13 we need separation between the two facilities and there's a lot of coal ash around 14 any coal plant and we want to avoid disturbing that.
15 But we'll have a lot of information from the previous operation of the coal facility.
16 And so I guess the question is going back to the first one, how can our how can our 17 review be efficient even though that because we've occupied that site for a long time 18 we'll have more data, but coal to nuclear reuse. Brownfield site looks a little bit 19 different than others have described it, however, makes a lot of sense to repurpose 20 that facility for both the Community and the land.
21 Minimize transmission impacts, the water resource impact is just translated from one 22 generating facility to another.
23 And so how can NRC consider that in doing their environmental assessment? A lot of 24 times when we talk about doing good environmental work, we go down into the 25 details. But from a macroscopic grand scale, a site reuse makes a lot of sense and so 26 how can the staff empower itself through changes to guidance to say hey, this site 27 could have two futures, one is repurposed as a nuclear power plant, the other as a 28 loss of jobs, loss of tax revenue and an idle facility that just stands on unused. And so 29 I think there's an opportunity - from a Brownfield site to look at the bigger picture.
30 And look at the holistic impacts and say hey, it makes a lot of sense to repurpose this 31 site.
32 And I guess the last question I'll ask is why is a met tower a critical path for NRC 33 issuing any license or permits?
34 And so I'll go into a little bit of detail of what that means. So, the first announcement 35
43 of the site is a commitment of the company to the Community and so those aren't 1
made lightly and a lot of planning and decision making goes into that.
2 But to site a met tower, I have to pick the site first.
3 I can't order them at Tower and design it before I've picked the site because every 4
county has its own standards and rules and every county has its own zoning 5
requirements.
6 So if I do a region of interest of my whole service territory, look at a lot of sites, I 7
can't really start that met tower work in parallel and I can't really put in a zoning 8
application until I've announced the site to the public.
9 So, so the announcement of the site to the public is first, then then we work on the 10 zoning applications. Then we construct the Met Tower. Then we start collecting data.
11 So you're probably 6 months in from the time you announce the site till when you're 12 actually collecting data.
13 And you collect a year of data, do the evaluation, do the submittal. So even though 14 it's critical path, you still haven't completed the two years of data. You know at some 15 point we're going to be able to show - which we already have - that the local airports 16 around - their data is pretty consistent with what we're getting for our met data.
17 And so I don't know if the staff has an appreciation of why the Met Tower's critical 18 path, but I think if you ask the staff what are the most important things in doing a 19 review, the Met tower probably isn't in the top 10.
20 And so what are ways we can, in accordance with guidance, use the Met Tower in 21 conjunction with local data from National Weather Service to be cooperating to 22 allow alternate means of demonstrating the same level of reasonable assurance.
23 And I guess I guess the last point I would make is population centers and 24 exemptions. So, plants tend to grow great communities, you know, if you look at a 25 coal plant, most of the cost is in the fuel and it leaves the community. You look at a 26 nuclear power plant, most of the cost is in the plant and the jobs and that creates 27 employment and tax base, and so communities grow up. So if we wanted to reuse 28 one of our existing nuclear sites, we would have problems with population centers 29 and exemptions probably are not an acceptable work around from a long term 30 standpoint.
31 So hopefully as the staff looks at the ADVANCE Act and implementing changes, 32 exemptions, and deviations from guidance or short term solutions and rulemaking 33 and guidance changes, or how the how we will see the future - because every 34 exemption, every deviation from guidance becomes a risk factor and it already is 35
44 a relatively substantial a financial investment over a 10 year period and so adding 1
additional uncertainty in the regulatory world doesn't incentivize deployment.
2 So I gave you a lot of information in a short time, but I also gave you time to ask 3
questions.
4 5
Sarah Lopas: Yeah. Well, that's really helpful, Chris. And what we are going to do is 6
we are going to just roll through the next two presentations and then go to the panel 7
discussion.
8 So hopefully you're OK with that if you can.
9 Can you stick around for another like 40 minutes or so? 40-50 minutes?
10 11 Chris Nolan: OK.
12 13 Sarah Lopas: OK, excellent. Thank you so much. Yeah, because, I got your questions 14 written down and I'll introduce you, Greg Cullen, Vice President for Energy Services 15 and Development at Energy Northwest. Thank you, Greg.
16 17 Gregory V. Cullen: OK, so I think you know maybe similar to Chris, what I'm going to 18 try to do here is use our specific example, as you know, maybe a great opportunity to 19 illustrate some opportunities that the ADVANCE Act provides and to really provide 20 maybe a series of things that that.
21 That will put some, you know, reality, I guess potentially to what we're talking about 22 here.
23 For those of you that don't know, our site probably has some unique aspects to it 24 that may not be true of any other site, or at least very few, and that will mix a lot of 25 these concepts together. And so again, I think it could just be a really interesting case 26 study for us to think about practical ways to address some of these opportunities. Let 27 me so I'm going to walk you through again. Some things about our site just to kind 28 of lay some of that groundwork and then I'll get into sort of the I guess the meat of 29 some of the opportunities that we see.
30 First of all, our site is located on the DOE Hanford Nuclear Reservation.
31 We lease our land from the US Department of Energy.
32 We are in the state of Washington.
33 What is, you know again?
34 I'll come back to some of this later, but you know the shouldn't be lost on anyone 35
45 that not too far away from our site out here on this - on the Hanford Reservation -
1 there is just-completed construction of a waste vitrification plant and so a lot of you 2
know, theres that analytical work and data that's gone into analyzing that, including 3
a lot of seismic work and other things. So that's obviously relevant to what we're 4
talking about as well.
5 Again, you can see some data on the right, many of them, many of it, you're 6
probably aware of, but I'll go through some of this as I go through some of the other 7
slides too in a little bit more detail.
8 So this is kind of a look at sort of what we look think of as three distinct sites.
9 Co-located Columbia Generating Station is on the left. Obviously an operating plant 10 has been operating since 1984.
11 Had its license renewed in 2012 and just started the period of extended operation.
12 A lot of obviously the seismic reevaluation has been done in the last 10-12 years, 10-13 20 years or so on that site.
14 Again, meteorological data - a significant amount of data that comes from being 15 adjacent to this operating nuclear site.
16 But sites one and four here are the former Washington Nuclear project one and four 17 sites that did receive construction permits that were issued back in the 70s and WNP 18 One was around 75% or so complete when it was terminated.
19 WNP 4 about 25 or 30% complete when it was terminated, but each one of course, 20 had, along with the construction permit environmental impact statements.
21 Around allowing nuclear construction on those sites.
22 Here's kind of just some looks back in time.
23 If you will, during the construction phase and a lot of the activity that was going on 24 there, the levels of sort of impact to the land during that time.
25 Here's kind of a quick picture of the previously disturbed land from all that that it on 26 these sites.
27 Let's see. One of the things I did want to highlight on this picture actually, and I 28 Do I have a pointer tool?
29 I probably don't, but so on the Columbia generation site generating stations site, one 30 thing, the cursor, OK, if you see that this little brown rectangle right here.
31 It blends in very well. It's really hard to distinguish, but there is a brown rectangle 32 there. That is actually a DOE still owned and responsible for high level waste burial 33 ground. And there are conversations about how to eventually remediate that, but 34 there's some pretty, pretty high-level stuff buried right there. The lease footprint kind 35
46 of carves that land out so that DOE still kind of has access and control of that. It is 1
discussed in Columbia's final safety analysis report.
2 There is kind of beneath the entire site here, here are groundwater monitoring wells 3
all around this and below this site there is a basically a tritium plume in the 4
groundwater that comes from the some of the Hanford activities, and we believe 5
some potentially from this high level waste burial site.
6 So there's just some interesting aspects that come with that.
7 Again, a lot of data that's known about that and what's what, all is happening here. A 8
lot of groundwater monitoring already in place.
9 That kind of factor into overall assessment of environmental impacts and kind of tie a 10 little bit into some of the concepts that were brought up earlier around like 11 decommissioning.
12 All right.
13 This is a look at kind of what it looks like today. So we have remediated these sites, 14 we have entered into restoration activities.
15 Based on agreements with the state of Washington, the US Department of Energy, 16 and the Bonneville Power Administration, who had remained sort of the responsible 17 organization for funding that restoration, we have completed those restoration 18 activities.
19 We're in final sort of steps with the state of Washington and DOE to kind of close out 20 some of the waste disposal sites that we put on here and those sorts of things.
21 But again, a lot of activity done in the last years, including revising the lease to 22 discuss the restoration activities. And so again a lot more done and known about all 23 these activities in recent years, including some environmental reviews associated with 24 that work.
25 This is kind of a look then sort of looking at the southeast corner of Site One, which 26 is really the place that we intend for the first deployment of small modular reactors.
27 I should point out as well though that I think from when you look at that the how 28 closely located sites one and four are these two sites were originally reviewed from 29 environmental standpoint together back in the original construction permit process.
30 These were these were sort of reviewed as a contiguous site, if you will.
31 All right, so some things that we see kind of coming out of this as far as 32 opportunities really quickly, just a review of what we're thinking right now.
33 We are looking at the Part 50 process. And starting with the construction permit, we 34 do intend to be a fast follower to the first X Energy deployment down in Texas.
35
47 And the Dow Chemical project that is also, of course the DOE Advanced Reactor 1
Demonstration program, first deployment of the X Energy technology.
2 So we intend to follow that. We'll have a lot to be learned from that from a licensing 3
standpoint around the safety aspects in particular, so that'll be a key part of our 4
strategy.
5 We do see then, that given that a lot of the safety aspects of the licensing should be 6
something that we are duplicating, if you will, then we do see that the environmental 7
reviews, the site specific aspects are going to be sort of the key driver for us in terms 8
of schedule and cost from a licensing standpoint.
9 And so there are several things that we opportunities we see here, including 10 leveraging existing site data, which there's a lot and we'll talk more about that a little 11 bit, but how we can again then use that to avoid having to collect new data similar to 12 what Chris just talked about, we don't believe we're going to need or should need a 13 met tower and two years of collecting data. We have a ton of data about this site.
14 These two sites we have a lot of ground water monitoring wells already.
15 We have a lot of historical data from the previous licensing activities and a lot of 16 other information as well as a possibility of leveraging the GEIS.
17 Some specific aspects called out in Section 206 are sort of relevant to this site as well.
18 We do have existing transmission to the site we have by the way. We have already 19 entered into the Bonneville Power Administration generation interconnection process 20 and so they we are in their process for them to evaluate the readiness of that 21 transmission to today's standards and world, and with all the way that grid has 22 evolved, keeping in mind from a polls and wire standpoint, of course, the 23 transmission lines were originally intended to carry an additional 2400 megawatts of 24 nuclear generation away from the site.
25 So we don't think from a polls and wire standpoint that we would even need to add 26 transmission. There may be some upgrades needed to certain equipment, but again 27 that'll all be finally determined by the Bonneville Power Administration's review 28 process. From a cooling water standpoint, this kind of the photo I have on the right.
29 The pump - there is a pump house down at the river for the site four, as well as the 30 one here for Columbia. So that pump house is intact and actually still has spots for 31 the pumps to be installed. The intakes are already in the river. We have recently used 32 that pump house for a new surface water potable water system to the sites and so 33 we actually have introduced water through those intakes, into the basins, and are 34 using that actively right now. Of course, there's power there and then there are water 35
48 lines that run all the way up to the main part of the site.
1 So again, from an environmental impact standpoint, the fact that we do not have to 2
install any sort of intakes in the river, we think provides a significant value. The intake 3
design is the same as what Columbia uses. So it has a lot of recent data including 4
some fish entrainment studies that were required by the state to continue to keep 5
our permits active for that.
6 So again, a lot of data that we can carry over from that design to the sites one and 7
four intake design that could be very useful and helpful.
8 We do have roads on the site or that would have to be built, but there are quite a 9
few roads accessing the site already, as well as railroad access that comes right up to 10 the edge of the site right now, and the community port of Benton. The community 11 owns those railroads and is committed to activities to bring those up to today's 12 standards to be ready for transporting components and materials to the site.
13 Again, just thinking about existing information that's out there, I talked about some 14 of this already, but all the information about Columbia that we know from its history 15 as well as all the activities during its operational period, including the license renewal 16 process, the reviews from WNP one and four construction permits, including seismic 17 and flooding back then, as well as updates on seismic and flooding hazards in 2014, 18 which was done not only for the Columbia site, but it was actually parts of this work 19 done by and sponsored by the Department of Energy for the entire Hanford 20 Reservation. So again, we've very comprehensive information in a lot of those areas 21 that goes well outside the bounds of our specific sites.
22 So again, that's kind of spelled out here in the next bullet about the Hanford geotech 23 and hydrology. Hanford actually issues - I think it's annually or every few years -
24 actually issues sort of an environmental assessment update if you will for the entire 25 site. So again, something that's kept very, very current far as specific information.
26 The decommissioning - I referred to it as decommissioning because of the language 27 in 206, but of course in our case, since there were not actually operating reactors, it's 28 just restoration activities. Clearly, clearly then doesn't have all the same 29 comprehensive information that was referred to earlier, but as I mentioned earlier, a 30 lot of activities - that a lot of information that is known from those activities 31 including environmental reviews.
32 And then finally the nuclear experience and supportive community.
33 You know, Chris talked a little bit about this with his sites.
34 And clearly with Columbia Generating Station operating there, we've got a 35
49 community that's very comfortable with that generating facility being located in the 1
community. But you know it should also be pointed out that that beyond that - the 2
entire Hanford operations and clean-up activities are the largest employer in the 3
community. We have a significant number of folks employed by that that are very, 4
very experienced and comfortable with nuclear.
5 We have Pacific Northwest National Lab. The second highest employer in the 6
community.
7 That brings again a lot of scientific information and knowledge and perspective on 8
nuclear.
9 So we have a community that is actually very proud of its nuclear legacy, very, very 10 experienced, knowledgeable, educated and comfortable with nuclear and quite 11 frankly spends more time pushing us to bring this year and go faster than they do 12 providing any sort of concern or opposition. So you think about what we talked 13 about in a lot of communities with operating nuclear plants - that they are very 14 comfortable and supportive, but then multiply that by a pretty good factor when you 15 think about a community that also has a DOE site that's the largest employer and a 16 national lab, that's the second largest employer.
17 You know, just threw in a couple thoughts here, too, that, you know, obviously a lot 18 of overlap with section 506 and the ability to use existing information that we already 19 have.
20 So I know there's no need to remind you of that. But just a very relevant to what 21 we're talking about here.
22 Let me talk about some other specific things to what we're thinking about and 23 attending both in terms of challenges and opportunities, but some goals.
24 The first one here, you know, we are deploying - our intention right now is to deploy 25 the X Energy technology. The design would support up to 12 modules on a single 26 control room - a single, you know, base infrastructure if you will.
27 And so our intention would be to license this project for 12 modules from the start, 28 even though the only, you know real, if you will, active funded, you know, offtake 29 agreement in place kind of scope would be the first four modules. So we would 30 intend to take a licensing approach that licenses all 12 up front with the idea that we 31 would build four first and we don't know if we'll ever build the remaining 8, or when 32
- that's similar to, you know, it basically uses a lot of the concepts of the NuScale 33 design really. It kind of broke ground for if you will, in terms of that, you know, sort 34 of a bounding size but with ability to sort of implement reactors on an unknown 35
50 schedule. But that means our environmental reviews would be intended to do the 1
same thing - sort of bound those 12 modules from the start. As I mentioned earlier, 2
there's even some sense that we could potentially do our environmental reviews for 3
both sites one and four from the start, looking at bounding 24 modules because it is 4
very much a plan of ours that if this project goes well and we continue to have the 5
same need and interest that we have then we would move right next door to site one 6
and continue on. So, any opportunities we have to, you know, provide bounding 7
analysis that just avoids having to repeat those activities for the right next door site, 8
we would love to pull in right up front. An interesting sort of challenge for us, and I 9
don't really know that it's going to be a major challenge for what you're doing, but 10 just something I thought I would point out for you guys to keep in mind.
11 Section 206 references the CERCLA definition of a Brownfield site.
12 And something we've run into, you know, the investment tax credits.
13 The Inflation Reduction Act sort of did the same thing, sort of pointed to the CERCLA 14 definition.
15 And what we have found is that if you pull the string on that and go into the CERCLA 16 regulations, there's a little parenthetical statement that says basically federal land, 17 federally owned lands are excluded.
18 Everyone we talked to in Department of Energy or in Congress has basically said 19 clearly no one intended for that to exclude a situation like ours where we're leasing 20 the land from the federal government and using it for non-federal activities.
21 Nonetheless, that's the words that are in there right now.
22 So we are working with Congress. There's a draft bill out there right now to 23 potentially fix that issue for the tax credit piece, but it is something that, you know, 24 we should keep in mind here. I don't think, you know, given the nature of how the 25 ADVANCE Act is constructed, that it basically directs the NRC to, you know, find ways 26 to be more efficient and list sort of example ideas of things that should be 27 considered. You know, I don't believe that if there are any advantages that could be 28 brought to our sites out of Section 206, I don't know that there's any challenges with 29 being able to leverage those in other ways on the project anyway. So I don't know 30 that it's an issue, but something that we just would ask you to keep in mind and 31 something that we may want to have further discussions on how that could maybe 32 be dealt with during the rulemaking process when you get to that point.
33 And then one other challenge that we face that we're facing right now that is 34 something that that we would like you to keep in mind as well.
35
51 The NRC process, of course, for environmental reviews and the and the construction 1
permit and on into the operating license stuff, obviously is very well laid out and 2
proven, including the historical, you know, opportunities for beginning non-nuclear 3
construction before the categorical exclusions and other areas.
4 But one of the things that we have run into is that, you know, like anyone, we are 5
dealing with multiple stakeholders on our environmental review.
6 And so just a picture for you. You know, these are all the kind of the entities that 7
we're dealing with that have some interest in the results of the environmental review.
8 Obviously, the Nuclear Regulatory Commission and the construction permit process, 9
we would expect to be the lead agency on this, but the Department of Energy, 10 Hanford Field Office, our leaseholder, would need to be revising the lease to allow 11 for nuclear construction.
12 And it was revised previously to focus on the restoration activity, so it would need to 13 be revised again to support nuclear construction and operations, and they're going 14 to want environmental review as part of that lease revision as well.
15 We also intend right now to pursue financing of the project through the DOE loan 16 Programs Office, which would have its own NEPA requirements associated with that.
17 And then of course, our state permitting process as well.
18 And now again, both DOE Hanford Office and the Washington State Energy Facility 19 Site Evaluation Council are perfectly comfortable following the NRC as a lead agency, 20 letting them do the primary review and just following that process.
21 They've expressed that multiple times.
22 That's how it's been done historically.
23 However, one challenge we face that particularly in the state, but also we see this 24 with DOE Hanford Field office, you know their processes don't support the idea of 25 segmenting a project. And so what they've sort of indicated - what the regulations 26 would indicate right now is that we could not do any activities associated with a 27 project at all - no site grading. We can do site characterization things that would go 28 with evaluating that as a potential site. But once we say this is where we want to 29 build it, there are no activities we can do until the environmental review is complete 30 and the state does not really have right now the multiple levels of environmental 31 reviews that that, for example, DOE does. So the one challenge we face right now is 32 that if we just follow the standard process of letting NRC be the lead agency and the 33 environmental impact statement is not really issued until the construction permit is 34 issued, then what that means is we're not able to do any construction or site prep or 35
52 anything at all until the construction permit is issued, and obviously that's a major 1
impact to the schedule. So one of the things that we have already met with NRC staff 2
and talked about some of this in more detail. So I don't intend to get into this in 3
great detail here, but we are trying to come up with ways to sort of maybe separate 4
the environmental review from the construction permit itself and you know, maybe 5
get that in earlier try to get that out earlier so we can get state permitting and things 6
done and allow us to go ahead and start working on non-nuclear construction 7
activities while we wait for the final construction permit.
8 So it's just another reason why, for us, you know that again there, there have been 9
some that have said given that we're following the Dow project, given that we would 10 have that licensing and that construction permit process right in front of us, 11 happening in front of us, that the environmental review might be our critical path 12 from a licensing standpoint. What we're saying is that we just can't afford a licensing 13 review that just takes a standard two-year time and flows and comes out with the 14 construction permit. We really need this to be an efficient effective process to allow 15 us to get through some of the other permitting processes in order to start prepping 16 the site and be ready for that nuclear construction once the construction permit is 17 issued. So more work we're doing there to work with both the state, the NRC and 18 DOE, to try to really develop the best path we can come up with.
19 But it just illustrates the importance of why the environmental piece of this needs to 20 be very efficient, effective, and particularly you know what I've laid out here I hope 21 would show a great opportunity to implement exactly what the ADVANCE Act is 22 asking for, right? That there's so much information. There's so much history, there's 23 so much surrounding about this site and activities that have been done here, 24 including a lot of nuclear work beyond, you know, associated with the Hanford and a 25 very supportive community, existing infrastructure, there's just so much about this 26 site that should drive a very, very efficient environmental review process. You know, 27 perhaps even just a simple update to the environmental impact statements that were 28 issued previously. But as Chris said, just making sure that we avoid, you know that 29 actually becoming more complicated just because we want to understand a whole 30 bunch of differences and end up having to provide just as much or even more 31 information.
32 So anyway, hopefully that's helpful as a case study and you know a way that we can 33 kind of use to kind of frame out and think about some of these opportunities.
34
53 1
Sarah Lopas: Yeah, that's great. Thank you, Greg. OK. To get two more 2
presentations, one if Caroline Cochran from Oklo, if you're online still, Caroline, we 3
will go to you.
4 5
Caroline Cochran, Oklo:Hey, thank you. Yeah. Yeah, forgive me.
6 7
Sarah Lopas: Oh, I hear a baby. Excellent.
8 9
Caroline Cochran, Oklo: Yes you know as timing would have it, he just started 10 fussing right as you called my name. So, we'll see.
11 We got a 2-month-old, so I guess that's my excuse.
12 13 Sarah Lopas: Oh, my goodness, congratulations!
14 15 Caroline Cochran, Oklo: Thank you. Thank you. All right. Well, unfortunately I got 16 looped into this a little a little late compared to our SODI friends and you know but 17 wanted to take the opportunity to speak to this if possible. So, I put together some 18 slides, but too late I think for them to be able to be shown here. So, I'll just speak to 19 the project a little bit off the cuff, if that's alright and go from there.
20 21 Sarah Lopas: Yeah, of course. And would you prefer Christine to speak ahead of you 22 if you want to, if you want to take care of baby first, it's totally up to you.
23 I don't mind crying baby, but if you feel distracted, we can have Christine present first 24 for a little bit and then come back to you if that would help.
25 26 Caroline Cochran, Oklo: If you give me one minute, I think I'll find a solution here.
27 Thank you.
28 29 Sarah Lopas: Yes. OK. Yeah, no worries. No worries at all.
30 31 Caroline Cochran, Oklo, OK. Oklo has been involved with SODI now for a couple 32 years. Got to know the site a little bit better. Starting in 2023 we announced a 33 partnership with SODI. And we also announced land rights agreement with SODI 34 earlier this year.
35
54 So we're at an earlier stage, I'd say, than some of the other presenters, but do have 1
some thoughts and maybe would just echo some of the things even Greg was just 2
talking about related to some other projects. Not exactly a traditional brownfield, but 3
we're also working in Idaho on a site that's very close to areas that have already 4
been, you know, developed. So maybe some similar insights as some of the other 5
presenters have mentioned.
6 So just a little bit about SODI for the audience in case theyre unfamiliar. It's a 7
regional initiative aimed at clustering economic development in southern Ohio.
8 So SODI stands for Southern Ohio Diversification initiative. And it's a really neat 9
partnership between DOE and SODI in order to try to develop that region on the -
10 there are several sites - one of which I'll speak a little bit more to, but that DOE has 11 owned historically for many decades and is cleaning up. And turning over to this 12 nonprofit, who then tries to seek out companies to partner with to do economic 13 development, so they're not just trying to turn around the land and sell it to whoever 14 will buy it. They're really trying to think through what is good for development in that 15 region and what would suit best the makeup of the workers and the communities 16 there. So, it's really a supportive engaged group for that region and partnering with 17 DOE in terms of cleaning up land and turning it over to be used in this way. We were 18 really excited about specifically this site called the Port site for short. Port stands for -
19 well, I'm forgetting what Port stands for, but I will say it's the previous site of the 20 Piketon uranium enrichment facility.
21 It's about 3777 acres located there near Piketon, Ohio, which is about an hour South 22 of Columbus. For those that are familiar. So, it's down in Southeast Ohio.
23 And so that's the site of a former uranium enrichment facility.
24 In the development of that uranium enrichment facility, originally, there was 25 incredible infrastructure put in place there. So, one of the biggest switch yards, I 26 think in the country, great rail access. Road access obviously - it's located 27 approximately in toward the center of the country. So, you can reach different areas 28 fairly quickly. And so, there's a lot of reasons why that site's exciting to us - of course 29 that infrastructure, but also the workforce has historically - for you know such a 30 small, kind of a remote area, has probably unusually high support of nuclear 31 generally. There's a complex history, of course, with the clean-up of the land and 32 effects on the community, but I'd say they've generally enjoyed a higher standard of 33 living because of the high paying jobs there that were, you know, diminished 34 because of the reduced, you know, use and so I think you know, any opportunities to 35
55 kind of re engage that workforce that is generally supportive like I said, but also 1
highly trained on average and there's some great local unions as well.
2 So an interesting chance to work with SODI and work with this community to think 3
through a nice site for some of our power houses, and we've been looking at it for 4
other facilities, too. But specific to this conversation, especially related to the 5
ADVANCE Act and licensing, the powerhouses seem most relevant to speak to.
6 So you know what? Some of the siting related to the powerhouses obviously 7
mentioned the knowledgeable and supportive community, but also it's not a highly 8
populated area, a high density area. The land is already developed, so you know, like 9
we've been talking about generally in this whole meeting, you know, less concern 10 about disturbing sensitive habitats or cultural and historical resources there, you 11 know, it's already been kind of developed. There are some other things about the 12 Port site. Obviously, I mentioned the switchboard access and the rail access, but 13 there's also interesting things like DOE still operating, has some operations there, as 14 they're performing clean up and so forth. So, they have some security resources 15 there. They also have developed high pressure firewater supplies and stuff like that, 16 so certain areas of the land at Port have these other things that are of interest to 17 development for a nuclear power plant. They, like other presenters, have talked 18 about some other sites. They are already very well characterized sites, so there's 19 meteorological monitoring that's been going on for a long time. It's generally 20 seismically stable, but also there's already an existing NRC licensed facility there in 21 terms of Centrus has their enrichment facility in their operating a certain amount of 22 enrichment activity going on right now, under you know, of course intersect 23 licensure. So you know, when we look at that site and I'll probably just wrap it up 24 here.
25 I don't have much more to say, but I wanted to speak to some of our thoughts 26 around potential NRC efficiency gains or things that we think about the site that 27 could enable that, of course, in this case, DOE already has a lot of operations on the 28 site and has been performing meteorological data procurement, cleanup, water 29 monitoring, et cetera. But what could we think NRC could find beneficial out of that?
30 Is that you know if NRC could utilize existing NEPA evaluations and other evaluations 31 and data reviewed by other federal agencies - in this case DOE - it seems like a 32 chance for increased efficiency. Similarly, you know, it's not just NEPA. I think there 33 are other evaluations and other data, you know, there's already been another site 34 license there for the Centrus enrichment facility. Granted, it is not exactly the same 35
56 kind of licensure, but may be harder in some ways, because of enrichment in terms of 1
security studies and other types of studies, but also, you know, one of the things I 2
haven't heard as much discussion about, but is, you know, leveraging existing 3
emergency planning and plans, security plans, and so forth. So obviously site-specific 4
stuff is interesting NEPA environmental data, meteorological data, but also I think, as 5
we think about, you know, operations of a plant, we think about things like 6
emergency planning, security plans, and things like that. So not just from industry 7
considering preexisting evaluations and data from another federal agency, but 8
preexisting evaluations and data from the facility itself but applied to other facilities. I 9
think one of the things we think about other data, existing data as well and use of 10 that and hopefully gaining efficiencies due to existing data, is you know how can 11 potentially older data be used? It's understood that maybe meteorological data can 12 change over a decade time span, especially as we believe we're all experiencing, you 13 know, climate shifts currently. But I would say seismic data is maybe more stable.
14 So if seismic data for example is more than 10 years old, that meteorological data is 15 not. Maybe you know at least the seismic data could be used even if it's a little older 16 or if there could be a process for qualifying such data, I think that's one thing that 17 that our siting team has identified as they look at using the site.
18 Now last thing that I'll mention in terms of efficiencies, this is something that Oklo 19 discussed with the NRC previously and not just related to Brownfield sites, but I think 20 in terms of siting efficiency in general and just as applicable to Brownfield as any 21 other site is, you know, asking the NRC to consider allowance for use of USGS data 22 for seismic analysis. It was developed differently, but it is generally in place from 23 most, if not all, locations in the United States. In other words, you can interpolate 24 between different data points that exist all across the country, and it does include a 25 certain amount of soil characterization, etcetera, for situations when, you know, 26 potentially the safety margins are large or there's enough bounding that it's 27 comfortable to utilize that data - that would significantly I think streamline siting 28 licensing. Because seismic is often the long pole in the tent. And this data is readily 29 available for all sites in the country. This is data used for buildings of various types 30 throughout the country currently. And so especially maybe if you don't have a safety-31 related building and things like that and your safety case is such that it allows for 32 that for the intersectional use of data like that in order to streamline Geotechnical 33 characterization of the site.
34
57 So that's pretty much everything I have to share for today's event, but I'm happy to 1
answer any questions.
2 3
Sarah Lopas: That's great. Thank you, Caroline, if you could just hang on for just a 4
few more minutes, we're going to go to Christine next, and then we're going to just 5
do the panel discussion. So, grab your baby and listen in, thank you so much.
6 7
Caroline Cochran, Oklo: Thank you.
8 9
Sarah Lopas: All right, Christine, you are on. Oh, and do I.
10 I need slides for you. Don't I have slides for you? I apologize.
11 12 Christine Palmer King: So I'll go ahead and talk a little bit the primary purpose of 13 this last piece is really you know we've talked a lot about the nuts and bolts and 14 we've hinted and in some cases openly talked about the need to engage the 15 community. And you know, and there's different types of communities out there, I 16 think. If so, my slides are really about sharing a little bit about what we've seen in our 17 pilot study. And then some of the research that came out of 2024 study that was 18 done by the Department of Energy on Workforce.
19 And the reason that Sarah asked me to talk about this is that.
20 These conversations are a little bit different than and maybe our speakers would be a 21 little bit different associated with community engagement, energy, justice and 22 environmental justice so.
23 Alright, so going back to a slide that Doug shared earlier in this meeting, our corner 24 generating station work, we started this work. It was initiated with the St. John's 25 mayor's office. But one of our reasons for interest in this area is there are adjacent 26 coal stations that also have retirement dates as well. And so one of the positive 27 results out of this discussion was sharing what we learned at Coronado with the 28 neighboring state. In Springerville and the discussions that have emerged, in the 29 community there as well as between the utilities that own those assets in Kentucky at 30 the generating station, we share the results. What becomes interesting at that 31 particular location are its neighbors, and we shared the results with the industrial 32 customers nearby. And so, there are ongoing conversations with folks like Nucor and 33 Dow Chemical, who have been in the news and expressed interest as having nuclear 34 energy in the future, but they actually live adjacent to the Ghent Station there in 35
58 Kentucky. In Colstrip, as we finish the project, we know that we're going to be 1
presenting the results not only to Northwestern Energy and the other owners and 2
the town of Colstrip, but also engaging with the state senators and the governor's 3
office so those conversations are not necessarily about the nuts and bolts that you've 4
heard today.
5 In terms of reuse of the site and whether you would connect to the secondary side 6
and those types of things, if we can go to the next slide.
7 This 2024 study there's two documents here. I reference the information guide, which 8
is the shorter version.
9 There is a longer version of this report if you'd like to see it, but basically what we did 10 was expand on what we learned from some of the pilot studies.
11 Looking at what can a nuclear power conversion offer a community based on 12 employment numbers which you see in the left hand side there based on plant 13 capacity and when you look at that, we see a trend that - and this was based on 14 publicly available information from the developers that have posted job numbers -
15 so there was about three or four different designs to look at for this particular study -
16 but you see a net gain in jobs on the right hand side, you see the income for 17 community. I pulled out the information looking at a smaller community, less than 18 20,000. Generally, though, what we found is nuclear has a multiplier of 1.5. So, every 19
$100.00 of electricity produced you get $50.00 of induced economic activity through 20 your suppliers and your support industries and things like this.
21 So when you think about that in terms of a small community, this is a significant 22 amount of dollars. What's not in this calculation is balancing the lost tax revenue 23 they have from the closure of a coal station.
24 And let's go to the next slide.
25 I think I was most excited about this part of the work.
26 So when you ask a research economist about overlap and job types and education 27 levels, whether we knew it or not, I did not, we all have an occupation code, and that 28 occupation code tells you your level of education and the type of work that you do.
29 The skills that you need to do that work. So, in comparing the occupation codes 30 between a coal plant and a nuclear power plant, we found that 45% of those jobs 31 have an identical occupation code, and then in addition to that, there was up to 72%
32 that had similar occupation codes. And that means that they were one digit off, 33 which might mean you need an extra certification but it doesn't mean that we're 34 sending people back to college to be able to make the transition from a coal plant to 35
59 a nuclear power plant. What's shown in the graph here is you can see in terms of 1
quantity of people. And the education requirements generally, there is a good match.
2 You see a little bit of a difference out there in bachelor's degree and master's 3
degrees. And in the report, if you would like to look at that, you can see in more 4
detail of where those gaps emerge. Next slide.
5 Our pilot studies and our work in Community has actually led to five communities 6
coming forward through the Community's local energy action plan. Which was 7
something that Doug mentioned earlier as well. In Eastern Kentucky, northwestern 8
Colorado. Rosebud and Treasure counties in Montana. Southwestern Pennsylvania 9
and Utah's coal country, which is southeastern Utah. The communities have asked for 10 technical assistance to explore nuclear energy, these projects are underway at this 11 time and will be completed by September of 2025, so I would encourage as we go 12 into future conversations about this or as you explore this, you know, to make 13 connection with the folks that asked for this technical assistance to get their 14 perspective and I think this is where energy justice and environmental justice - the 15 lines start to blur a bit. There is a coal communities transition team led by Salt River 16 Project and Tucson Electric in the northeastern Arizona area. That might be a good 17 resource to discuss. Pueblo County, in Southeast Colorado published a report on the 18 PIESAC report that I have there. It was done in conjunction with Excel, and it was 19 about the retirement of the Comanche station and they have had ongoing town 20 meetings about, you know, investigating nuclear energy.
21 And not all of this is to say that all of the people listed here are gung ho and excited 22 about nuclear energy, but it is to say that we see communities trying to lead, as I 23 mentioned before, in parallel or partnering with the utility that might own that fossil 24 asset. And that is all I had that was meant to be a teaser to come back when Sarah 25 tells us to come back and talk about this in more depth.
26 But it is a it is a different driver, but equally important to how we look at our 27 brownfields and understanding that they're beyond the pumps and the valves and 28 the water and the land and all of that, there is a human aspect here that should not 29 be dismissed.
30 31 Sarah Lopas: Yeah, alright. Thank you, Christine. Alright, so we're going to move 32 right into panel discussion. Did so, did anyone anybody want to kick off in the in the 33 room?
34 35
60 Allen Fetter: So, Chris, you who you asked what if Brownfield site look like to the 1
NRC? You know it's not an NRC definition. It comes through the EPA and then we 2
had the definition earlier - it's pretty broad. It says that any a site, any real property 3
that has any contamination or potential contamination that could affect 4
development of the site. Now, as I gave an example in the other slides, a lot of the 5
sites we've licensed for new plants have been fall under that definition around field 6
site. And as far as the NRC, not that we don't care, but that we don't have necessarily 7
regulatory with respect to it, right? For example, if potential non-radiological 8
contamination is identified during site characterization, it would be described in an 9
environmental impact statement as part of a sites baseline condition. If 10 contamination is identified during activities associated with building a new plant, a 11 licensee typically would inform the NRC construction inspectors, but that issue would 12 not be under NRCs regulatory purview and NRC would not halt construction 13 activities. Rather, the issue of identified contamination would be a matter under State 14 regulatory purview (potentially EPA) and a licensee would need to engage with the 15 appropriate entities for feedback and potential corrective actions.
16 17 Chris Nolan: Just to just to respond to that. You know the reason I asked those 18 things in the forms of questions is to engage a conversation and I think if you go into 19 this exercise focused on contamination, you will get to a different outcome than if 20 you went to this conversation as repurposing an industrial facility and what I would 21 encourage you to do is broaden the aperture because I think the solutions for one 22 and the solutions for others can be the same. Ans just like the experience with Kairos 23 and the discovered contamination from a historical site, that is a risk that any facility 24 you know will incur when they when they repurpose either adjacent to or identically 25 on an industrial site. And so, Greg, I'm sure is going to have some discovery at his 26 site and we're going to have some discovery at our site.
27 But you would probably characterize them differently if your focus was 28 contamination and not repurposing an industrial facility.
29 So I asked the question for you to actually think beyond the word contamination as 30 you identify. Your opportunities to make a more efficient process that the comment 31 that Greg brought about his site just spurred a neuron - is why do we have to link 32 the safety review and the environmental review together so closely in time?
33 I mean, the Canadian process has separate hearings for both that are separated in 34 time. A lot of the regulatory risk is on the environmental side. And if we if we front 35
61 loaded that as a project it would de-risk the overall deployment equation. And so I 1
guess what I'm asking you to do is think broader than the word contamination.
2 3
Sarah Lopas: Yeah. Oh, and just to be clear - the bifurcated review thing, Chris, 4
because that's important. And Greg mentioned it, too. I know that is something we're 5
considering. I think, Greg, I think there's some aspects to maybe Section 106 and 6
having an undertaking. I mean those are some of the things that may complicate it -
7 with the National Historic Preservation Act - that may complicate that a little bit in 8
terms of we can't when we can begin initiation of that Section 106 consultation.
9 So those are some of the things that we need to think about a little bit, but the 10 bifurcation of these two reviews is something that's definitely on our radar for sure 11 and something that we're going to have to continue to pursue.
12 So thank you for bringing that up. That's great.
13 14 Sarah Lopas: And just to Chris's point, we understand that the underlying purpose of 15 what Congress is looking at is to ask you to look at the repurposing of sites. Our 16 focus is not on contamination, right? And I would think all these efficiencies in terms 17 of using existing data, you know, how can we streamline our reviews, are clearly 18 applicable to a Greenfield site that happens to, for whatever reason, have a ton of 19 data, maybe just not what you would call a Brownfield site, right? But Chris, I do feel -
20 having worked on the Duke, the Williams States Lee review for a little while at least, I 21 can promise you there will be no repeat of that review for sure. I mean, if anything 22 we have at this point, very firm guidelines in terms of page length and times that we 23 have to complete these environmental reviews in. So, we will not be repeating that, 24 but I want to... Peyton, I see your hand raised. You can go ahead and unmute 25 yourself and share your camera if you would like.
26 27 Peyton Doub: This is Peyton Doub. I was one of the colleagues on the Lee review.
28 And use of that previously disturbed site was indeed very efficient from an ecological 29 point of view, and that most of the site had been previously disturbed, and that did 30 help facilitate our review. And if that was the only complicating impact on the site, 31 we would have concluded very rapidly and easily without a lot of analysis that there 32 were small impacts. But one of the complicating factors was the need to construct an 33 off-site reservoir that required flooding of a of a greenfield stream valley. And a lot 34 of the additional review that the colleagues had to do pertained to that rather than 35
62 the site itself. So, use of sites like that from an ecological point of view, it's very 1
efficient. And very, you know very much in the spirit of conserving ecological 2
resources, but I just want to make sure that the Lee experience was put in 3
perspective. Now if that site were chosen to build a plant that didn't have the water 4
demands and the offsite reservoir weren't needed then that would indeed be a much 5
faster environmental review from an ecology standpoint.
6 7
Chris Nolan: So, I appreciate that. I appreciate that, Peyton.
8 I also worked on the Lee application and I would say that the comments about the 9
construction permit and the COL ER stand independent of Make Up Pond C. Make 10 Up Pond C was a supplement. I think we saw the dynamic between the construction 11 permit and the COLA before. The supplement on the Make Up Pond C. So, I think 12 Make Up Pond C was a scope change. We had a 500-year drought that occurred in 13 the middle of the - I guess it started right as we were submitting the application and 14 it continued through the review. And so that was a big impact. But I think the 15 comment I made about the Construction Permit stands alone.
16 17 Sarah Lopas: Yeah, understood. Hey Joe Giacinto, I did see you raise your hand. So 18 go ahead and raise your hand, Joe, if you want to pop back on. But I saw you raise 19 your hand.
20 21 Joseph Giacinto: Well, I'll, I'll just speak up if that's OK. I just wanted to point out 22 that, you know, we don't have to wait until a CP is issued to issue an environmental.
23 Impact statement. So, we can actually do that before. Before the hearing and we 24 have a process for supplementing that if we need to, or at a minimum, we'd evaluate 25 any new information and just submit that as part of the record at the hearing stage.
26 So I just wanted to make that point.
27 28 Sarah Lopas: Thank you for that clarification, Joe. Appreciate that.
29 30 Sam Lee: I would just throw out the usual just because there's no prohibition, does it 31 mean everyone involved knows it's a possibility, so that could be an opportunity to 32 spell out - Here are the many opportunities that are available, and if there's more 33 information needed on how to execute that either from an applicant requesting or 34
63 staff initiating - that could be used OK.
1 2
Allen Fetter: So, I want to call on Kevin Quinlan or Jason White regarding Chris's 3
third question is why met data met towers, critical path and there was reference to 4
Reg Guide 1.23 and II understand there's a new Reg Guide 1.249 and I'm not sure if 5
that speaks to that - Kevin or Jason, can you are you online?
6 7
Kevin Quinlan: I heard - if you could repeat the original question that would be 8
helpful.
9 10 Allen Fetter: Yeah, I'll just say, you know what Chris was saying. And he was 11 wondering, you know, the Met Tower data being critical path about the cost of it and 12 having two years of, you know, required data. And my understanding is there's a reg 13 guide - an alternate maybe alternative met data under Reg guide 1.249 might be 14 used as initial at atmospheric dispersion analysis.
15 Can you speak to that? I don't want to make sure I'm not speaking out of turn.
16 17 Kevin Quinlan: Sure. So, the we have our Reg Guide 1.23, which I'm sure everybody 18 is, at least anybody who works with the meteorological data is already familiar with 19 which states that for a construction permit they only need one year of 20 meteorological data to be collected before they submit. So, it's not the two years.
21 The two years is for an operating license and I believe for a COL. So you know, for a 22 construction permit it would, it would only be one consecutive 12 month period.
23 As far as Reg Guide 1.249 goes, this was written as an option for what the Reg Guide 24 is specific to the use of the ARCON atmospheric dispersion model, which typically is 25 used for on-site atmospheric dispersion factors to the control room - so, control 26 room, habitability model. But we wrote a guide for how to use it for off-site.
27 Look off-site receptors within about 1200 meters of the site. So, but we also 28 reorganized that for some of these sites. They may not have an onsite meteorological 29 tower, so we put in a section for alternative meteorological data and stated that it 30 was for use of the ARCON model. This is a way that they could use alternative 31 meteorological monitoring approaches for use of the ARCON model.
32 And it does go through - it does not give an exhaustive list - but it does go through 33 and give ways that applicants could use other reliable sources of meteorological 34 data, such as National Weather Service, FAA, EPA, Department of Defense, DOE 35
64 facilities, things like that, where they have reliable data and what they could use as 1
ways to justify the use of that data at a site.
2 So again, it's not an exhaustive list, but it does provide a good list for what would 3
need to go through in order to use alternative meteorological sources at a sight.
4 So hopefully that made sense. I'm certainly happy to try to address any questions.
5 6
Allen Fetter: Yeah. And I would also add, if there are, if there are any applicants or 7
folks who are interested in engagement with NRC staff on, you know, the guidance 8
on ways that are acceptable to follow it and things that might be unique to a specific 9
site - because that seems like it could be an opportunity that, you know, because we 10 have heard about the Met information, Christine.
11 Thanks Kevin.
12 13 Christine Palmer King: Maybe the maybe to raise this up a little bit of a level here, I 14 think what I heard from this panel. And I guess my question is to the panelist is I 15 think what we're looking, I think what they're looking for is, an acknowledgment of 16 some equivalencies. And some benefit from already knowing a significant amount 17 about these sites, even if it is not an exact match. And so I do think where even if 18 we've had regulations in the past, they give you an alternative way - maybe looking 19 at the experience that that these three have had already to understand if that 20 regulation serves them well now. And maybe, Greg, you're far enough into it. Or 21 Chris, you're far enough into it to have a comment on that.
22 23 Gregory V. Cullen: I think I want to maybe speak for Chris, but at the risk of you 24 know, maybe being a little more frank than he's willing to be, I think.
25 And Christine, I think is doing a good job too. You know, just sitting here watching 26 this, you know, I think Chris posed what I would consider to be somewhat rhetorical 27 questions, right. In terms of how do we rethink the future and the purpose of this 28 task force or this group and this and ADVANCE Act is to rethink how we do these 29 things. And again, just for feedback for you.
30 You know, I'm a little concerned that the answers tend to be the standard.
31 Here's the way we do it.
32 Here's our reg guides.
33 Here's the way it's always been done, and I think again, the point Chris did not need 34 to know why met Tower is critical path from a current red guide standpoint. I think 35
65 Chris is challenging, why should it be?
1 And why can't we come up with better ways to do that?
2 So I just would challenge this working group as you go forward.
3 Yeah, I think each one of these is an opportunity to be thinking about the future.
4 And I think you know what Kati laid out is the challenge in front of us is, is we have a 5
lot of guidance.
6 It's been built and regulations have been built for the existing light water reactor 7
fleet and now we have technologies that are made huge advancements in how we 8
design in safety, in some cases having eliminated the possibility to melt the fuel 9
right? So, so, so how do we read all this and how do we avoid ending up with, you 10 know, reams and reams of exemptions that, as Chris said, create some risk for all of 11 us in terms of public perception. And instead, how do we create a process here as 12 driven by the ADVANCE Act to make sure we're fully recognizing all these 13 opportunities and creating the new pathway to do this better and more efficiently?
14 And where again, we're not sacrificing safety in any way.
15 We're saying we've got better ways to invest safety now.
16 Let's create an environmental review and a licensing process that recognizes 17 advancements, takes advantage of existing information, and charts a much better 18 way.
19 So Christine, I don't know if that's what you were prompting for and trying to say 20 very much more nicely than me, but.
21 Chris Nolan: So, Greg, I think your comments were right on the money and I think 22 NRC right now is going through an answer the mail process where I asked a 23 question. They're giving me a response about the existing process and your 24 discussion about what I was trying to accomplish was right on point.
25 So, Kevin, you didn't apparently have the benefit of hearing my discussion. So I'll just 26 go through it.
27 So we are working on an ESP at the Belews Creek site. The Met Tower is the critical 28 path. And the reason is the critical path is because we couldn't design the Met Tower 29 until we picked the site, right? And we were down to two and they were in different 30 counties and the counties have different standards for construction.
31 So we had to pick the site before we could start building the Met tower and then we 32 had to announce the site before we could do the zoning changes so that we could 33 put the met tower up. Collecting data, going to submit on one year data. Push the 34 schedule but I have lots of data from the local airports and I already know the Met 35
66 tower tracks with those local airports so I know that you're getting lots of challenges 1
of why do I need a met tower can why can't I use air airport data?
2 Maybe there's a way to say, well, if you have a met tower and it's already checking, 3
then you don't need as much data, or there's other ways of doing it, but my 4
rhetorical question, why is the Met tower the hardest thing?
5 From a schedule standpoint and getting a permit and so you guys can answer the 6
question literally or you can think about your process and say you know what really 7
makes sense.
8 9
Kevin Quinlan: Sure. And thank you, Chris, that having that background information 10 was, is very helpful. Having not joined the discussion until 10 minutes ago, I certainly 11 missed that that whole part. So I appreciate that so.
12 13 Chris Nolan: So, Kevin, I feel your pain. I get thrust in those kind of dynamics all the 14 time. I think your answer was spot on.
15 16 Kevin Quinlan: Well, I love hearing that as well. So, thank you. But, but you know to 17 get to your point though, it is a, it is a topic that we have been thinking about.
18 It's a topic that has come up a number of times over the last year or so, so.
19 I think and we have seen some examples of use of alternative meteorological data.
20 How it compares to an onsite program is always tricky. I think the following Reg 21 Guide 1.23 and putting up an on site met Tower - that's despite the schedule 22 implications of it, which I certainly understand - that is the easy button. That we know 23 if a program is run to the specifications in that guide, it not only is representative 24 directly of the site, it's to the emergency planning and atmospheric dispersion 25 thresholds or the data quality that we know we need for those models to have 26 confidence in the results when we get the results from those models. If you're using 27 meteorological data from an alternative source, that's from a few miles away 28 depending on the location that may be, you know, it may be very similar to the site.
29 Some sites certainly can't say that if the meteorological station from a National 30 Weather Service from an airport - they have varying quality the way that they 31 measure things like atmospheric stability are completely different than the way that 32 our models use that parameter. So data conversion has to happen.
33 Then how that happens, you lose some quality there as well. So there's a lot of issues 34 that go into using alternative meteorological data sources for the purposes that we 35
67 use the meteorology data. But not that it can't be done. It's just it takes more like 1
work, more justification, more data manipulation.
2 3
Chris Nolan: So, Kevin, our experience has been that the Weather Service is pretty 4
good unless the site has a unique characteristic like River Valley flow that that shows 5
that the local conditions are different than the global conditions.
6 But you know, we're going through that process now for our Belews Creek site.
7 You know, I've never thought about working the equation backwards. You have a 8
met tower and then you can correlate data with the local weather station.
9 Is there a way to do calculations before you actually have a year of data.
10 I don't know. I haven't thought about it, but as you go through your discussions 11 about process efficiencies, if you want to look at what we're doing as a comparison, 12 you're more than welcome. We're more than happy to engage with you.
13 14 Kevin Quinlan: Yeah, I think the more engagement, the better that that's usually my 15 philosophy.
16 17 Gregory V. Cullen: But just for the sake of you know, using this opportunity to think 18 about the future, again, I'll just throw out for our case. For example, right?
19 If I am, I have a an existing nuclear plant operating at the right next door.
20 I should have plenty of information, or at least I had enough information at one point 21 to license that facility and I've maintained its operating license. So if I'm deploying a 22 technology that, let's assume that, that you know, X Energy can prove the fuel safety 23 case. If I am now deploying next to Columbia generating station, a technology that 24 that has a fuel I can't melt. Then to me, there's no world in which I should have to 25 come up with new and different meteorological data. That if just because maybe 26 we've, you know, raised the bar on the standards of instrumentation and those sorts 27 of things. So that's a challenge I would lay out to you just that weve got an 28 operating plant that's been licensed and now I'm deploying a safer technology.
29 30 Kevin Quinlan: Sure. So, I mean in that case that that's come up a dozen or maybe 31 dozens of times, but many times where an application comes in for a new unit that's 32 Co-located with an existing unit and we don't require a new tower. They use the 33 exact same tower as the existing units. It was that way for Summer, Vogtle, Turkey 34 Point, PSEG. All of those sites have existing units there and they just used the on site 35
68 meter logical tower that exists at the site as long as they submit two years worth of 1
data for again for a COL, or an ESP or construction permit would be one year. As 2
long as it's within the last 10 years, that's all our guidance asks.
3 We certainly would not request or require a new tower to be put up in that case.
4 5
Christine Palmer King: So, Kevin, I think one of again, apologies to you for being 6
thrown in, but here you are. So welcome to the crowd.
7 8
Kevin Quinlan: Sure, I'm here. Glad to be here.
9 10 Christine Palmer King: You know, one of the challenges we've seen in the work that 11 we've done. Sorry I'm with GAIN and we've been doing some pilot studies with coal 12 stations. So similar to the types of sites that Chris is considering, you know these are 13 operating stations that have lots of information about their site.
14 They may not know one thing in particular, the height of a met tower for coal station 15 is not the same height as required for a nuclear station. And so one of the things I'm 16 curious about is, is there a pathway by which - because I find it surprising that the 17 Met tower becomes critical path - when you start to lay out these projects and these 18 types of things, but is there, is there a way to accept through equivalency that that 19 data from an operating site or from a recently decommissioned site? I mean, I guess 20 I'm curious about the difference in that data and whether we know how much it 21 changes the uncertainty band on the calculation or the preciseness of the calculation 22 at the end. I do not do these calculations. This is not something I've ever had to do in 23 my career, so I am at the end of my expertise but that. Those are the kinds of 24 questions that come up in my mind.
25 26 Kevin Quinlan: Sure. And I think they're the right questions to ask.
27 I think you could probably understand my reluctance to answer.
28 29 Christine Palmer King: Yeah. The purpose of this meeting was to share thoughts 30 and experiences from those of us that have been looking at some specific instances.
31 As you guys are doing your work on the ADVANCE Act, we this not trying to impugn 32 anyone at all, just trying to share.
33 34 Sam Lee: So if I could just step in for a second here, this is Sam Lee, NRC.
35
69 So I think the question that you ask is a reasonable question and I think it's a 1
reasonable request - can we consider and this is not to dismiss the you know, what 2
Kevin has said about you know looking at the data and making sure, but I think, but I 3
think at a higher level the question is very reasonable - is that if we can rely on the 4
data, can we look at existing data to make a decision? I think at a high level that the 5
answer to that is yes. You know, this is not a decision on a particular licensing action, 6
but it's a question of feasibility and I think with that we have an opportunity to look 7
at this and see what we can do better in the spirit of addressing the ADVANCE Act 8
and what we can do better, more efficiently.
9 10 Sarah Lopas: So it's 4:41 and in the spirit of letting everybody free from this 11 meeting on time I do want to go - because we've had a people couple people -
12 public attendees raise their hands. So all right, I see Rani. Go ahead, Rani.
13 You should be able to enable your mic.
14 Just introduce yourself and go for it.
15 16 Rani Franovich (Nuclear ROSE Consulting, LLC):
17 Hi, Sarah.
18 Can you hear me?
19 20 Sarah Lopas: Yep, we can.
21 22 Rani Franovich (Nuclear ROSE Consulting, LLC): Great. So first great to see you, 23 Sarah, and thank you. Thank you for so deftly serving as MC of this informative 24 meeting and exchange of perspectives and furtherance of the ADVANCE Act, I and 25 others particularly appreciate your kind sensitivity to Caroline's juggling act. So nice.
26 Nicely done. Also great to see my many former colleagues and for and current 27 friends in the environmental COE from NMSS. As well as Sam Lee from NRR and 28 Tony Dimitriades from Region 1. Great to see you guys. So, second, I'm also pleased 29 to see this collaborative engagement with Christine King and her capable team from 30 GAIN, experts from EPRI, and inclusion of a second panel with real world industry 31 perspectives informed by experience, this is a really great venue for an exchange of 32 perspectives.
33 So, Chris Nolan asked a question about how the NRC might or should consider the 34 benefits of using a Brownfield site. And the question I think has merit, particularly as 35
70 it relates to the permitting reform provisions of the Fiscal Responsibility Act of 2023.
1 Particularly section 321, the Builder Act, which has a NEPA reform provision that 2
would call for a reasonable range of alternatives to be examined under NEPA to the 3
proposed agency action, including an analysis of any negative environmental impacts 4
of not implementing the proposed agency action in the case of a no action 5
alternative. But I think using a brownfield versus a Greenfield site falls elegantly into 6
the same kind of consideration. Would a Brownfield site perhaps have a better 7
outcome from an environmental assessment, as the panelists have argued.
8 Greg also mentioned that the environmental review for a CP before site preparation 9
work begins would be critical path for deployment at Columbia Station. Given the 10 growing demand for clean energy and urgency to meet climate demands while 11 securing energy independence, I think the NRC has a great opportunity to come up 12 with some creative solutions and I look forward to seeing how the staff challenges 13 itself, to Greg's point, to rethink and evolve its requirements in a manner that offers 14 flexibility for applicants to at least begin the process of pursuing brownfield sites 15 without the need for costly, burdensome exemption requests. Now some applicants 16 can tolerate risks to capital investment and their enterprises before securing a 17 construction permit. But NRC pre-approval of construction should not limit the 18 benefits of civilian use to radioactive materials and nuclear energy technology to 19 society. Lastly, the staff knows where pinch points in NEPA. And other statutory 20 mandates constrain regulatory flexibility and I encourage the NRC staff to identify 21 them for Congressional relief through Legislative action, review, and amendments of 22 existing statutes. Proactive action by the NRC in this regard would further advance 23 societal interests as intended by the ADVANCE Act, and that's all I wanted to add.
24 Sarah, thank you again for the opportunity to speak and it's great to see you all.
25 26 Sarah Lopas: Thank you, Ronnie. Appreciate that.
27 Next up, we have Brian Grimes.
28 Brian, you should be able to unmute yourself.
29 30 Brian Grimes: Yes. Does that work?
31 32 Sarah Lopas: That works, we hear you.
33 34 Brian Grimes: OK. So, I have a comment kind of a big picture comment and then a 35
71 question on the study group scope. The big picture comment is I was had a long 1
career with NRC and issued a lot of construction permits and a lot of those had 2
research and development angles that did not need to be resolved until the 3
operating license stage and for meteorological information, there's absolutely no 4
safety implications until the plant starts operating. So, I think as long as the applicant 5
is willing to take the financial risk of things coming out wrong that some general 6
assumptions could be made. And the meteorological data could be left till the 7
operating license stage. My scope question is - Where does a facility that is replacing 8
a gas furnace high temperature steam and industrial facility fall in terms of 206 for 9
the study group's purposes? The main thing is, there are a lot of things that are 10 involved in replacing industrial steam and one of them is making sure that the steam 11 is released for unrestricted use - so there's no implications of NRC licensing the 12 actual industrial facility. And so, there's a lot of angles there including hazard.
13 But I'm wondering whether this study group or the 206 study group will be 14 considering those aspects.
15 16 Sarah Lopas: We're including that in 206, right? 206 has a broad mandate -it's 17 basically like all NRC facilities essentially that fall under AEA section 103 and 104 18 which we were told is all production and utilization facilities, so even the steam 19 facility - so that would fall under this umbrella of this review as well.
20 21 Brian Grimes: OK. Thank you.
22 23 Sarah Lopas: OK. Next, we'll go to Adam. Let me unmute or let me allow your mic.
24 You are finally. You are finally unleashed. Adam, go. I'm sorry about that earlier 25 today.
26 27 Adam Stein - Breakthrough Institute: Thank you very much.
28 I appreciate the opportunity to speak. This is Dr. Adam Stein with the Breakthrough 29 Institute. There's been some great discussion by both the panelists and the NRC staff, 30 so I really appreciate that this meeting has been run a little bit differently than most 31 of the ADVANCE Act meetings. With less public comment, but in the place there has 32 been a lot of great dialogue with the panelists. So, I do appreciate that. I'd like to 33 know how I can provide further comment because the time is limited. Right now, I'd 34 also like to bring up just a few points that relate to prior discussions with my own 35
72 experience.
1 I was going to bring up Reg Guide 1.249 as using alternative meteorological data.
2 It's already approved by the NRC for a different application. In finalizing that I 3
provided comment on that Reg Guide suggesting applying it to, for instance, siting 4
decisions as has been discussed, at this meeting at the time I was told it was out of 5
scope. They were focusing just on that reg guide. There are several other cases where 6
things of that could be applied more broadly, have been considered out of scope for 7
things like the issuing one reg guide. The team is focused on the task they were 8
given, understandably, and does not necessarily want to look across instead of just 9
vertically. In discussion with the staff at the time of working on that reg guide, we 10 contributed a lot of comments on the ability to consider potentially bounding 11 analysis that relate to decision making, whether the uncertainty that is inherent in not 12 having a met tower that is the configuration the NRC is used to does change the 13 data. You have to calculate equivalences. For instance, stability factors as Kevin was 14 mentioning earlier. And so, there's a little bit of that created when you do these cross 15 calculations. But that uncertainty doesn't necessarily change the decision making. If 16 the output of a larger sense of uncertainty still is well below what the NRC would 17 consider sufficient, then that kind of approach can be used to streamline regulatory 18 decision making. You only need to sharpen the pencil to the point where it changes 19 the decision. In relation to the population center, discussions related to reg guide 4.7 20
- I provided comments saying that about 1/6 of existing nuclear sites would not be 21 considered generally suitable because of population density, as resulted from 22 population growing after the sites were constructed. The population grew to meet 23 the needs of power operating facilities. 1/6 of the facilities is a large portion of the 24 facilities out there and I'm sure the NRC would say those facilities are operating 25 safely relative to the population nearby. And we should consider that if the NRC does 26 consider those sites to be safe for the population nearer them, they already have an 27 operating facility, they should still be considered safe for another reactor in that 28 exact same facility. That issue is exponentially compounded when you look at 29 brownfield sites such as coal facilities or natural gas plants that have closed that are 30 closer to population centers. And I suggest the NRC look at that issue in earnest as 31 well. And finally, in relation to environmental reviews, I do suggest that the review 32 should directly consider whether taking the action actually results in leaving the 33 environment better than it was found, which is a major consideration for a Brownfield 34 site. The action might have impact. It might even have moderate impact. But that 35
73 impact from taking the action still could result in an environmental footprint that is 1
better than it was founded. Thanks for the opportunity to provide these comments.
2 3
Sarah Lopas: Greg, I saw you had your hand raised.
4 5
6 Gregory V. Cullen: It actually was unrelated to that. I had a final thought for you.
7 Somewhat unrelated, but if we run out of time, that's no problem.
8 9
Sarah Lopas: Alright, we'll go right back to you. Yeah. So, Adam?
10 So there is the ADVANCE Act portal where anybody can submit comments via that 11 way. But I don't think you can submit attachments via the portal unfortunately.
12 So there's a Contact Us ADVANCE Act site if you just use your favorite search engine 13 of choice and look, search for NRC and advance act contact us and it pops right up.
14 However, if you have attachments that you need to send letters, etc., reports.
15 Those can go to either Allen or I. Our emails, you know, it's just Sarah Lopas. If you 16 can see my name at sarah.lopas@nrc.gov. But our emails are listed on the NRC 17 meeting notice, of course. All right. I'm going to take the next. So, we're going to 18 hear from Adam Brown. Adam, let me enable your microphone here.
19 And you should be all set. Adam, go ahead, Adam Brown.
20 If you're there, Adam, you have to unmute yourself though.
21 I cannot unmute. I cannot unmute people, but he can unmute himself.
22 23 Adam Brown: Is that? Can you hear me now?
24 25 Sarah Lopas: Oh, now. Yep. Now I can. Yeah.
26 27 Adam Brown: OK. Alright, sorry about that. Thanks a lot for having this meeting.
28 And going through some good presentations.
29 There was - I do have a comment with regards to the Brownfield sites and of coal 30 plants and some of the challenges of remediation that might be faced as fly ash, 31 significant PCBs, and lead and asbestos are to be expected and a lot of the newer 32 plants would have been monitoring their groundwater for fly ash contamination. But 33 my question is, is just one of clarity, with regards to the population density of less 34 than 25,000, you're saying communities? But the slide that I saw listed it as counties.
35
74 So just for an aspect of clarity, is that 25,000 or less apply to a county or a 1
community, surrounding communities, thank you very much.
2 3
Sarah Lopas: It's the 25,000. Yeah. Maybe it's within - it's within a 25-mile radius.
4 5
Allen Fetter: The population center distance is the distance from the reactor to the 6
nearest boundary of the population center. NRC guidance recommends that the 7
population density within 20 miles of the reactor be no more than 500 people per 8
square mile 9
10 Christine Palmer King: So, the table that Kati had, that's from our report.
11 12 Kati Austgen: It might be that might have been the table from your report, Christine.
13 The yeah, the requirement from NRC is not to be within a population center. And 14 then further information clarifies that like political boundaries, et cetera, et cetera, 15 have nothing to do with what is the actual boundary of the population center. So it 16 all goes back to census data. Yeah, census data. That's it's outlined in the ESRP, I 17 believe.
18 19 Christine Palmer King: It was a screening analysis. We used county level data 20 because that was the easiest way. Instead of going around 1000 sites and trying to 21 calculate that - we didn't have access to the supercomputer, just regular computers.
22 23 Sarah Lopas: OK. Thanks, Christine. Let's we'll squeeze in these last two comments.
24 But Rani, I'm going to go first to Joy Jiang since we already heard from you once. So, 25 I'll start with joy and then we'll go to Ronnie and then we'll close out. Greg, we'll go 26 back to you. So, Joy, you should be able to unmute yourself and go ahead.
27 28 Joy Jiang: This is Joy Jung with the Breakthrough Institute, and I will be very brief if 29 we are already for 4:58 pm. So, I just want to continue on our director, Adam's point 30 about the population density. I think that is really a issue that NRC needs to pay 31 attention to. Because it's not only related to the brownfield sites development - we 32 touched upon that in the Part 53 public meeting yesterday and the day before 33 yesterday as well. And regarding the 25,000 threshold, I think it's a little bit more 34 prescriptive than what the ADVANCE Act would require. The ADVANCE Act requires 35
75 the NRC to develop technology inclusive risk informed framework. So basically, I'm 1
saying if you would consider advanced nuclear facilities or microreactors in the future 2
then how would this population density rule be applicable to those technologies?
3 Basically, I'm saying that NRC needs to consider this to avoid this rule becoming a 4
barrier in the future - no matter if it's brownfield or Greenfield - to development of 5
nuclear energy. Thank you.
6 7
Sarah Lopas: Thank you, joy. Alright, Rani, we're going to end with you with public 8
comments with you. So go ahead.
9 10 Rani Franovich (Nuclear ROSE Consulting, LLC): Thank you. Sarah, can you hear 11 me?
12 13 Sarah Lopas: Yep.
14 15 Rani Franovich (Nuclear ROSE Consulting, LLC): I'll be quick. I may have forgotten 16 to identify myself before, so Ronnie Franovich, Nuclear Rose Consulting LLC.
17 And that's it. Thank you, Sarah.
18 19 Sarah Lopas: Alright, excellent. Thank you. Alright, Greg, go ahead.
20 21 Gregory V. Cullen: Yeah. So, thank you so much for coming back to me, Sarah, and 22 thank you for this opportunity today. And I guess what I really wanted to do is leave 23 you with a couple thoughts, given that this may be my only chance to address the 24 larger process here. So, forgive me if these are slightly off topic.
25 The first one is, you know, I think it was Kati that made reference several times to 26 some of the efforts around micro reactors. And you know, I think for us, you know, 27 micro reactor requirements are going to break all our paradigms, right?
28 I mean, there's just so much about it that's going to be different, right?
29 They might be portable. They might be shipped back and refueled elsewhere, right?
30 So, I would encourage us to constantly keep that that micro reactor effort as 31 something that as it's breaking paradigms, how do we then go pull those back into 32 SMR licensing and environmental review. So just something to throw out there and 33 think about that. I think that's going to really help us think in new and creative in 34 different ways.
35
76 The second thing I'm going to throw out again, this is going to be - I don't want you 1
to respond to this - but this is going to be way off topic and a little out of the 2
ordinary, but recently, in the state of Washington. You're probably aware Washington 3
state passed a Clean Energy Transformation Act that says we got to be 100% clean 4
electricity by 2045, and obviously that drives a lot of what the state does.
5 Probably won't surprise anyone if I make the judgement statement that Washington 6
has been politically dominated for many years by very progressive environmental 7
perspectives, right? We recently had in the state a large wind, solar, and battery 8
project that was going to stretch some 20-something miles. All these ridges around a 9
major community in the state, and when it went to the state permitting there were 10 some issues with an endangered hawk species. And since a lot of things that got 11 pulled in and the Washington State Energy Facility Site Evaluation Council basically 12 scaled back the deployment of that by about half. When it went to the governor, the 13 governor sent it back and said we are serious about needing clean energy and that is 14 our that's our biggest priority, if you will. You need to relook at this project, and I 15 guess you know, on the one hand you could say despite the local community 16 significant opposition to this project, we have these objectives and I think that the 17 ADVANCE Act gives us a little bit of a peek at that, right? The clean energy needs are 18 built right into the title. I think the Mission statement adjustment for the NRC, you 19 know, starts to lean into this, right. There's a larger purpose or mission, if you will, 20 that starts to come into this in terms of the need for us to deploy clean energy.
21 So again really off topic. Don't want you to respond to just something. I'll leave with 22 you to think about.
23 How do we think about that as we go forward that these projects are critical to the 24 country and to what we're trying to do and how do we make sure we keep that in 25 front of all of us that you know in the end what we need to do is make sure we're 26 maintaining safety, which again I'm not asking for any reduction in safety review, but 27 we're meeting it in better and more designed ways upfront. How do we recognize 28 that in the process? And how do we just make sure we can deploy this in a way that's 29 really going to help us achieve what we need to achieve?
30 So, I'll just leave you with that, but thank you very much for the opportunity today.
31 32 Sarah Lopas: Yeah, thank you. Just before I close it out here, I do want to open it up 33 to any of our other panelists.
34
77 1
Christine Palmer King: Again, thank you for the opportunity for this discussion.
2 I am more than happy - we kind of gave you a whirlwind tour of a lot of stuff.
3 We are more than happy as you begin your work, if you have questions, to get into 4
the details. And talk about these things some more. So, I'm looking forward to 5
hopefully this was the first discussion.
6 7
Chris Nolan: And I would leave with this. I would just leave a thank you to you and 8
Allen for setting this up. I thought the forum was very constructive to a dialogue that 9
allowed points to be reinforced and made sure that there was clarity in the message.
10 So I thought it was very constructive use of my time.
11 12 Caroline Cochran - Oklo: Hi, yes, I just want to add my thank you to hosting this 13 meeting for the dialogue and having us on specifically. As far as last words, I don't 14 know if I can add this to the meeting materials, but maybe I could add some slides 15 that I was. Basically, speaking to but didn't present from during the meeting. Just to 16 add some other insights from our point of view.
17 18 Sarah Lopas: Yeah, that would be great. I if you haven't emailed them to e-mail like 19 to me.
20 21 Sam Lee: Thank you, Sarah. And I want to thank all the panelists for being here and 22 also virtually really appreciate your comments. You know at the at the 10,000-foot 23 level, the comment that I heard back today and if I were to just repeat some of the 24 theme here. Is that to view the ADVANCE Act as an opportunity to improve how we 25 do regulatory business? And I think that mindset is key. That we see it as an 26 opportunity to improve how we do business.
27 So with that, thank you all and thank you, Sarah and Alan and others for doing a 28 fabulous job of coordinating this meeting. And I want to thank my also, my fellow 29 NRC staff for the comments they provided as well.
30 So thank you all.
31 32 Sarah Lopas: Oh yeah, and thank you, Kati. I didn't even thank you, Kati. Any last 33 words? You know where to find us!
34 35
78 Kati Austgen: I know, and we won't be shy, but certainly, you know, happy to 1
connect further on any of the things that we've already created, even if they were not 2
publicly available. If you think there are insights that may be valuable, I'm happy to 3
work with you to find a way to share some of that information. And yeah, we'll be in 4
touch as we develop additional documents that we say, hey, this this could be one 5
way to do it. Thank you.
6 7
Sarah Lopas: Thank you everybody. Thank you, everybody online. Appreciate it.
8 Have a great evening or rest of your afternoon.
9 10 Sarah Lopas: stopped transcription at 5:08 p.m.
11